Crow v. Boeing Co.

*321¶1 Washington’s Industrial Insurance Act (IIA), Title 51 RCW, generally bars actions by workers against their employers for workplace injuries.1 This statutory bar is subject to the narrow exception that such an action is not precluded where an employer deliberately intends to injure an employee.2 Our courts have construed this provision to require that there be actual knowledge that an employee’s injury is certain to occur and willful disregard of such knowledge.3 Here, Scott Crow fails to establish any genuine issue of material fact for either of these requirements. Accordingly, we affirm…