Palmer v. Amazon: A Case Study In Textualism And The Fixed-Meaning Canon

14 Wake Forest L. Rev. Online 112

Authored by: Michael Showalter¹

Introduction

A recent Second Circuit panel failed to heed the fixed-meaning rule of statutory interpretation, and its flawed opinion highlights the rule's importance to the rule of law. In Palmer v. Amazon, the Second Circuit held that New York's workers-compensation exclusivity does not reach suits for injunctive relief. As in many states, New York statutory law provides that an employer's obligation to pay workers' compensation "shall be exclusive" and "in place of any other liability whatsoever" to an employee for workplace injury. All agree that the provision bars workplace-injury claims for monetary relief, but whether the provision also bars claims for injunctive relief—whether the word liability encompasses injunctions—is contested. The Second Circuit held that the provision does not reach suits for injunctive relief because (in the court's view) being enjoined does not make an employer l