A Texas appellate court upheld a $4.5 million jury award to a worker injured in a sawmill accident, rejecting arguments that the claim was barred by workers compensation exclusivity.
In Antonio Munoz Aserradero LLC v. Thomas, the Court of Appeals for the 12th District of Texas on March 11 found sufficient evidence that the injured worker may not have been an employee at the time of the incident, allowing his negligence claims to proceed.
The case stems from a May 2022 accident at a sawmill in Rusk, Texas, owned by Antonio Munoz Aserradero LLC. Jerry Thomas had arrived at the worksite after initially missing his planned start date and was told he would receive training before any employment decision was made, according to his testimony.
After being shown how to operate a slab edger, Mr. Thomas resumed work following a lunch break and was injured within minutes when the machine caught his arm near a moving chain mechanism.
Although the sawmill’s workers compensation insurer, Texas Mutual Insurance Co., paid medical expenses and indemnity benefits, Mr. Thomas filed a negligence suit, asserting he was not an employee but an independent contractor or invitee.
A jury returned a 10-2 verdict awarding $4.5 million in damages, assigning 40% responsibility each to the sawmill and the company, and 20% to Mr. Thomas.
On appeal, the defendants argued the trial court should have directed a verdict in their favor based on the exclusive remedy doctrine. The appellate court disagreed, citing conflicting evidence over whether Mr. Thomas had begun employment.
The court also upheld the exclusion of evidence that Mr. Thomas received workers compensation benefits, noting such evidence is generally barred under the collateral source rule because it may be more prejudicial than probative.
Similarly, the court found no abuse of discretion in excluding testimony suggesting Mr. Thomas had used marijuana on the day of the accident, concluding the evidence was either undisclosed, irrelevant or too remote.
The appellate panel further held there was sufficient evidence that Mr. Munoz exercised control over the premises to support individual liability and rejected claims of jury instruction error.
The ruling affirms the trial court’s judgment in full.