Julio Aravena, Etc. v. Miami-Dade County
Supreme Court of Florida
JULIO ARAVENA, etc.,
[April 6, 2006]
We have for review the Third District Court of Appeal's decision in Miami-Dade County v. Aravena, 886 So. 2d 303 (Fla. 3d DCA 2004), which expressly and directly conflicts with the Fourth District Court of Appeal's decision in Palm Beach County v. Kelly, 810 So. 2d 560 (Fla. 4th DCA 2002). We have jurisdiction. See art. V, § 3(b)(3), Fla. Const. The conflict issue is whether county employees who work at different physical locations for different departments, have different supervisors, and perform different duties and functions in their primary assignments fall within the unrelated works exception to workers' compensation immunity. We answer this question in the affirmative and conclude that the unrelated works exception was intended to cover this precise set of circumstances. We hold that although no bright-line rule governs, the unrelated works exception has both locational and operational components and requires consideration of several factors, which we set forth herein.
FACTS AND PROCEDURAL HISTORY
Miami-Dade County is the largest of Florida's sixty-seven counties, and its government comprises forty-five departments and approximately 30,000 employees. Gregoria Vega was employed by Miami-Dade County's Police Department as a part-time elementary school crossing guard. Her job was to help children cross the street at the intersection of Southwest 16th Street and 62nd Avenue. On October 24, 2001, the traffic lights at the intersection were not operating properly. As a result, two vehicles collided in the intersection and one veered off the road, killing Vega. Vega was standing on the swale of the road at the time of the accident, which occurred at approximately 7:20 a.m.
Julio Aravena, Vega's husband, initiated a wrongful death case against the county, alleging that the accident was caused in part by the negligence of the county's traffic signal repair personnel who failed to repair the malfunctioning traffic lights at the intersection. The traffic signal repair personnel worked for the maintenance section of the Miami-Dade County Public Works Department, which is located at 3655 Southwest 25th Terrace. The maintenance section receives information from the traffic control section of the Public Works Department, which is responsible for all traffic lights in Miami-Dade County and is located at 7100 Northwest 36th Street.
In response to the complaint, the county claimed that Aravena's action was barred by the portion of Florida's Workers' Compensation Law that accords tort immunity to coemployees â€