Provost v. Puget Sound Power & Light Co

In Provost v. Puget Sound Power & Light Co., 103 Wn.2d 750, 696 P.2d 1238 (1985), the Court held the Industrial Insurance Act (Act) barred the wife and child of an injured worker from bringing suit for negligent infliction of emotional distress and loss of consortium. While these claims involved a separate harm to the family members, the Court concluded the claims were based upon the injury suffered by the employee and were thus barred by the Act. Provost, 103 Wn.2d at 753-56.