## Facts

- James Jett was employed by Farrel Corporation.
- Lester F. Dunlap, Jett’s supervisor, accused Jett in a profane manner of being away from his machine; Jett replied similarly.
- Dunlap struck Jett, pushing him backward and knocking off his hat.
- Jett alleged resulting depression, disruption of home life, and workplace humiliation.
- Jett sued Dunlap for battery and sued Farrel in tort under respondeat superior for Dunlap’s intentional assault at the workplace.

## Issues

1. Whether an employee may maintain a common-law tort claim against an employer under respondeat superior for a supervisor’s intentional workplace assault.
2. Whether Conn. Gen. Stat. § 31-284(a) makes workers’ compensation the exclusive remedy and abolishes such common-law claims when the injury arises out of and in the course of employment.

## Decision

- The Connecticut Supreme Court affirmed judgment for Farrel Corporation.
- The court held that § 31-284(a) makes workers’ compensation the exclusive remedy for covered workplace injuries, barring common-law tort actions against the employer.
- The supervisor’s assault was a “personal injury” arising out of and in the course of employment within the Act’s coverage.
- Because the complaint alleged only a supervisor’s intentional tort (not an intentional tort by the employer itself), no exception removed the claim from the Act’s exclusivity.

## Legal Principles

- When an employee’s injury is covered by the Workmen’s Compensation Act, statutory compensation is the employee’s exclusive remedy against the employer.
- Section 31-284(a)’s abolition of “all rights and claims between employer and employees” for covered injuries bars common-law theories, including respondeat superior, against the employer.
- Employer immunity applies even when the workplace injury is caused by a co-employee’s or supervisor’s intentional assault, so long as the injury arises out of and in the course of employment.
- Absent allegations of intentional misconduct by the employer itself or a recognized statutory exception, a tort claim against the employer is barred.

## Conclusion

The court held that an employee injured by a supervisor’s intentional assault at work could not sue the employer in tort under respondeat superior because § 31-284(a) makes workers’ compensation the exclusive remedy for personal injuries arising out of and in the course of employment.


Jett v. Dunlap, 179 Conn. 215, 425 A.2d 1263 (1979)