Alabama Supreme Court Reverses Directed Verdict in Workplace Injury Case

Bradley reports that the Alabama Supreme Court has reversed a trial court’s directed verdict favoring the defendant subcontractor in a negligence case involving an on-site workplace injury, Marina v. Bama Reinforcing, LLC. 

The trial court had ruled there was insufficient evidence linking the subcontractor to the injury. However, on Nov. 8, the Supreme Court found that the lower court failed to view the evidence in the light most favorable to the plaintiff, remanding the case for further proceedings.

The plaintiff, a concrete finisher, was injured on-site at the construction of the FBI building near Huntsville, Alabama when he stepped on a piece of metal chair used to hold rebar. The subcontractor responsible for rebar installation had a contractual duty to clean its work areas.

Testimony revealed the subcontractor was absent the day of the accident, claimed not to cut metal chairs, and completed its work before the injury. However, it was the only company on-site using these chairs.

The trial court directed a verdict for the subcontractor, citing a lack of direct evidence linking it to the injury and pointing to shared cleanup duties among contractors.

The Alabama Supreme Court reversed, emphasizing that the trial court improperly dismissed evidence implicating the subcontractor. The Court noted testimony identifying the subcontractor as the only entity using metal chairs, plus evidence suggesting negligence in the cleanup. It rejected the trial court’s rationale, stating that third-party negligence did not absolve the subcontractor if its own negligence contributed causally.

Bradley notes that the case “highlights the challenges courts face when trying to rule as a matter of law with respect to legal issues that require a fact-intensive inquiry.” The subcontractor is looking at a re-trial and more fees and expenses. For litigators, it exemplifies the value of demonstrating a logical causal chain and clarifying overlapping duties among parties.