Byrd v. Richardson-Greenshields Securities

Female employees brought allegations of assault, sexual battery, intentional infliction of emotional distress, and negligent hiring and retention of employees. The Florida Supreme Court considered whether the workers’ compensation statute provided the exclusive remedy for a claim based on sexual harassment in the workplace. The Court found that applying the exclusivity rule of workers’ compensation to preclude all tort liability would abrogate the overwhelming public policy interest in outlawing and eliminating sexual discrimination in the workplace. The Court distinguished workers’ compensation, which addresses purely economic injury, from sexual harassment laws, which are concerned with more intangible injuries to personal rights.