Georgia’s Court of Appeals says the stabbing of a Dunkin’ cashier by an angry customer sits squarely inside the state’s workers compensation system, not the tort courts.
The ruling reverses a trial judge and orders summary judgment for Peachstate Concessionaires, which owns the store where Mekiah Bryant worked.
The panel concludes the assault grew directly out of her customer-service duties rather than any personal conflict.
Bryant’s shift on Dec. 5, 2020 started ordinarily enough. Court filings say Marquavis Goolsby and another person hit the drive-through, learned certain items weren’t available, and came back roughly 10 minutes later to complain about her tone and demand a manager.
After a brief exchange, Bryant stepped out from behind the counter and Goolsby stabbed her in the arm. Two years later she sued Peachstate, alleging negligent security and premises liability, along with emotional-distress claims.
The trial court tossed everything except the premises-liability count, saying a customer stabbing wasn’t a risk reasonably tied to cashier work.
The appeals panel saw it differently. The judges wrote that third-party assaults sit within workers comp whenever the motivation flows from job performance, unless the dispute is purely personal.
Bryant and Goolsby had no relationship beyond the store. Without her interaction as a cashier, the assault wouldn’t have happened, the court said.
And while “being assaulted is not an obvious part of most jobs,” that doesn’t exempt the incident from the exclusive-remedy bar when the causative danger springs from routine duties.
Because the conflict stemmed from dissatisfaction with Bryant’s service, Peachstate can’t face a tort suit.
According to our data, the decision aligns with a long string of Georgia rulings that route workplace assaults into the comp system even when the facts feel extreme, so long as the trigger traces back to job tasks rather than personal animus.
