Courtney v. Meyer — Safety Rule Violations Without Particularized Knowledge of Harm Do Not Establish Co-Employee Willful and Wanton Misconduct
The Wyoming Supreme Court affirmed summary judgment for a garbage-truck co-employee whose activation of lift arms—from the passenger seat, without seeing where his injured colleague was standing—caused serious hand injuries, holding that multiple safety-rule violations and a poor post-accident response do not establish the particularized knowledge of highly probable harm required to pierce co-employee immunity under the Wyoming Worker’s Compensation Act.