FLORIDA EXPANDS INTENTIONAL TORT EXCEPTION

Employee's injury was substantial certainty from employer's failure to respond to requests for new ladder did not require proof that employer concealed danger.

"Even though case law on the intentional tort exception to workers' compensation immunity is devoid of any defined test that will establish substantial certainty as a matter of law, it is evident that concealment of the dangerous condition is only one of several factors in a nonexclusive list. "

Bakerman v The Bombay Company, ___So. 2d____, 2007 WL 1774420 (Fla.), decided June 21, 1007