Will Kemp's Order to Reopen Georgia Really Shield Business From COVID-19 Liability?
Lawyers say Gov. Brian Kemp's order reopening "essential" businesses like tattoo parlors and barber shops may lead some employers into a "minefield" of litigation.
April 30, 2020 at 05:31 PM
7 minute read
The original version of this story was published on Daily Report
President Donald Trump's executive order reopening meatpacking plants shuttered because of COVID-19 is already drawing scrutiny from an array of labor and civil liberties unions, concerned that his declaration may also be used to circumvent legal protections for workers and the public.
But even that 1950-era legislation known as the Defense Production Act, which gives the president sweeping powers to requisition property, override state and federal regulation and offers some limited immunity for civil claims against company's ordered into service, doesn't shield employers from liability for knowingly putting workers at risk of physical harm.
Legal observers said the executive order signed April 20 by Georgia Gov. Brian Kemp reopening businesses. including health care and dental facilities, restaurants, nail parlors, hair salons, bowling alleys and tattoo parlors, may be overstepping his authority by offering a promise of liability protection he can't keep.
Those businesses were deemed so vital to the state's economic well-being that Kemp was willing to shrug aside advice from health experts, including National Institute of Allergy and Infectious Diseases Director Anthony Fauci and Trump himself, to order their doors open.
Amanda Farahany of employment firm Barrett & Farahany said employers are unlikely to dodge liability by claiming protection under the governor's order.
"Immunity and the law comes from Congress and the Legislature," she said.
"The real issue here is not going to be immunity under the law; it's going to be the difficulty of proving where someone got the COVID virus so they can prove unsafe working conditions."
While many of the affected businesses have said they'll still remain closed until the virus is contained, others have taken the opportunity to welcome the public, with unmasked diners chowing down and manicurists dabbing enamel on the ungloved nails of customers.
The order contained several guidelines requiring social distancing, the provision of sanitizer and safety gear and other measures.
It also seemed to offer a liability shield to those businesses, citing a provision of the Georgia code granting the governor emergency powers during a natural or human disaster, including a pandemic.
As quoted in the order, O.C.G.A. 38-3-51(j) says: "Any individual, partnership, association, or corporation who acts in accordance with an order, rule, or regulation entered by the Governor pursuant to the authority granted by this Code section will not be held liable to any other individual, partnership, association, or corporation by reason thereof in any action seeking legal or equitable relief."
Given the scope of businesses allowed to reopen under the order, the question becomes whether and to what degree a business may be liable for exposing a customer or worker to the corona virus, particularly if said employee is reluctant to come in to work.
Noting that Kemp's order allows for some services that are impossible to provide from 6 feet away, Farahany said observing federal and state guidelines for reopening businesses may help employers avoid liability.
Even so, their employers could still face liability or workers' compensation claims if their workers or family members get sick.
"If they're not providing a safe workplace that's a different thing, because that's a foreseeable hazard," she said.
Turnbull, Cain & Holcomb partner Bret Turnbull had a more nuanced approach.
"First, this is an unprecedented circumstance, and we're in a unique time in evaluating executive power, state power, and the authority the president has bestowed on these governors," Turnbull said.
"The thing is, when the governor put out that order to reopen, that essentially makes these businesses immune for negligence in how they've handled the reopening; it grants blanket immunity to businesses acting in conformity with the order."
Citing an "extreme hypothetical, if [a business owner] were made aware that somebody had coronavirus, and they brought them in and served them, they are entitled to immunity from liability as long as they were one of the businesses allowed to be open at that time," Turnbull said.
"That's the difficulty with immunity; it doesn't allow for circumstantial or case-by-case analysis. It can go too far," he said. "It's like tort reform—you can throw the baby out with bath water."
"As attorneys, we recognize this is uncharted territory for the governor and the businesses," he said. "What we don't what we don't want is a situation where people are damned if they do and damned if they don't
Parks, Chesin & Welborn partner J. Matt Maguire has a different take.
"I'm not a personal injury lawyer, but it does seem to me to be unconstitutional: Granting immunity to an entire class of people is a legislative act," said Maguire, who specializes in business and employment law.
"I think I understand where they think they have the authority. Once the governor declares a public emergency, he has the authority to promote and secure the safety of the population," Maguire said.
"I could see it if it was limited to healthcare workers and providers more narrowly, but that is still a function of the legislative branch," he said. "To the extent the statute is read as granting the governor the authority to immunize, I think that's an overly broad reading."
While the governor and state actors in general are almost entirely immune from suit under Georgia's sweeping sovereign immunity law, Maguire said a plaintiff "harmed by his action could still argue in court that the grant of immunity was unconstitutional."
Maguire said his firm has gotten several calls from people who don't think they have the coronavirus, but are afraid to go back to work.
While a claim would raise causation issues, he said, an employee who could prove exposure at work could still a workers compensation claim.
"We've been watching this fluid event unfold both as attorneys and as employers/business owners," said Jeff Shiver of personal injury firm Shiver Hamilton.
"Regarding liability immunity for employers and businesses during the pandemic, I would be hesitant to endorse such a broad approach," Shiver said.
"While it is true many businesses are doing the best they can to navigate an evolving situation—with models and data changing on almost a daily basis—we have heard stories of individuals and businesses acting recklessly and with disregard for the effects to their employees or other individuals," he said.
If there are claims of negligence arising from a business's handling of exposure issues, he said, each would need to be apprised case-by-case.
"As we see shelter in place orders relaxed, businesses will have to take reasonable and prudent steps to open their business and not endanger their employees, customers or others in the public," he said.
"'What would a reasonable prudent person do in the same or similar circumstances?" asked Shiver. "That simple question, the foundation for almost all negligence cases in Georgia, takes into account the unique challenges presented by this pandemic. And a jury can evaluate each case based on this standard."
A partner at a mid-sized Atlanta firm, who asked not to be identified, said the conflicting guidance from Kemp's office, the White House and federal health authorities will likely impact any litigation springing from the reopening.
"Some folks are going out on a limb typing to reopen the country, and we're already seeing people saying, 'yeah, we realize there's some responsibility in how this is handled,'" he said.
"It's always been the case in Georgia that you have a statutory obligation to provide a safe workplace—you can't have open hazards, you can't give somebody a broken ladder to work on, you have to provide goggles and masks."
"Now there's contrary guidance," he said. "Well have to see how it plays out before a jury a year from now. It's a minefield for litigation."
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