In Texas Workers' Comp. Comm'n v. Garcia, 893 S.W.2d 504 (Tex. 1995), employees found that negligence was difficult to prove and that employers enjoyed complete defenses in the common-law doctrines of contributory negligence, assumption of the risk, and negligence by a fellow employee. Id. The first Workers' Compensation Act replaced the common-law negligence remedy with limited, but more certain, benefits for injured workers. Garcia, 893 S.W.2d at 510-11. Employees could recover reduced benefits without proving fault by their employers or facing common-law defenses. Id. at 511. "In exchange, the employer's total liability for an injury was substantially limited." Id. Employers could opt out of the system but were discouraged from doing so, as the Act abolished all traditional common-law defenses for nonsubscribers. Id. Employees of nonsubscribers retained their common-law rights. Id. Although portions of the Act have been amended, this quid pro quo scheme has remained unchanged since 1913. Id. The core concept of the Act is the assurance that injured employees either have access to the courts to seek redress for wrongs or receive adequate substitute remedies. See Garcia, 893 S.W.2d at 520-21. The Texas Constitution provides an "open courts" guarantee: "All courts shall be open, and every person for an injury done him, in his lands, goods, person or reputation, shall have remedy by due course of law." Tex. Const. art. I, 13. Legislative action that withdraws common-law remedies for well-established, common-law causes of action satisfies the constitutional open-courts guarantee only when it is reasonable in substituting other remedies. Garcia, 893 S.W.2d at 520.