Jenny Velecela v. All Habitat Services, LLC.

Summary

The court held that the Workers' Compensation Act's exclusivity provision bars a survivor's negligent infliction of bystander emotional distress claim when the distress derives from an employee's compensable work-related injury or death. Because the plaintiff's emotional injuries were causally connected to her husband's compensable death, summary judgment for the employer was proper, regardless of whether the bystander claim itself was independently compensable under the Act.