Kuciemba v. Victory Woodworks, Inc.

Summary

The court answered two certified questions concerning employer liability for a spouse's COVID-19 infection allegedly transmitted by an employee. It held that workers' compensation exclusivity does not bar the spouse's negligence claim because the spouse's physical injury is not legally dependent on an injury to the employee, but held that employers owe no tort duty to employees' household members to prevent COVID-19 transmission because the resulting burdens on employers, courts, and society justify an exception to the general duty of care.