Otis E. Smith v. John B. Kelly, Inc.

WASHINGTON, Circuit Judge

(concurring) .

I agree that plaintiff-appellant is barred by assumption of risk. I wish, however, to draw attention to another aspect of the case. There is an increasing tendency, it would seem, for workmen who have been injured and who have received (or have been offered) Workmen’s Compensation benefits by their own employers to bring suit for damages against other employers of men working on the same job site, claiming that the negligence of these others produced the plaintiff’s injuries. Such suits are brought under the claimed authority of statutory provisions for recovery against “third-party” tortfeasors. Whether other employers on the same job site are third parties within the meaning of a particular Workmen’s Compensation statute is a question on which courts have differed. See Larson, *173Workmen’s Compensation Law §§ 72.00-72.50 (1952); see also Maddox v. Aetna Casualty & Surety Co., 5 Cir., 1958, 259 F.2d 51; cf. Jonathan Woodner Co. v. Mather, 93 U.S.App.D.C. 234, 236, 210 F.2d 868, 870, certiorari denied 1954, 348 U.S. 824, 75 S.Ct. 39, 99 L.Ed. 650; Recent Case, 108 U.Pa.L.Rev. 155, 162 (1959); Note, 39 Va.L.Rev. 951, 958 (1953). The problem has not been definitively settled for this jurisdiction. It was not raised by the parties in this case, and we do not reach it. Furthermore, the law of Maryland rather than that of the District of Columbia governs the instant case. But some day the problem must be faced, under the law prevailing in the District of Columbia.