In In re Autotainment Partners Ltd. Partnership, 183 S.W.3d 532, 536-37 (Tex. App.--Houston 14th Dist. 2006, orig. proceeding), the court addressed the applicability of an arbitration clause and disagreed with the real party in interest's argument that his claim, which sought damages for a fall he suffered, fell outside the scope of the arbitration agreement because his claim was for workers' compensation benefits.
The court applied the presumption favoring arbitration and did not address whether the damages that an employee recovered against his nonsubscribing employer for negligence constituted an "obligation" for which the employer was liable "under any" workers' compensation law. Id. at 537.