jurisdictions that reinforce an employee’s obligation to establish a prima facie case of negligence under those state’s respective statutes. See, e.g, Workman v. Anderson Music Co., 2006 Ok. Civ. App. 123, 149 P.3d 1060, 1062-63 (Okla. Civ. App. 2006) (refusing to view Oklahoma’s statute governing non-compliant employers as creating strict liability, and opining that if an employee sues under the statute, it “is incumbent upon him to establish primary negligence, and the injury and causal connection”) (citations omitted); Skinner v. Smith, 255 S.W.2d 621, 622 (Ky. App. 1953) (requiring as a pre-requisite to recovery that the appellee establish a case for negligence against the employer); Duncan v. Dickie Rector Lumber Co., 31 Tenn. App. 155, 212 S.W.2d 908, 911 (Tenn. Ct. App. 1948) (<HOLDING>) (citing, inter alia, Moore Coal Co. v. Brown,
holding that the statutory restrictions relative to an employers affirmative defenses where the employer elects not to operate under the respective workers compensation law cannot extend so as to deprive the employer of being able to require the plaintiffemployee to establish a case of negligence against the employer holding that in order to establish liability under the ada the plaintiff must demonstrate that the defendant was an employer within the meaning of the statute holding that glc 152 15 provides that the only party immune from suit under the statute is the direct employer a special employer is not immune because the special employer is not liable for the payment of workers compensation and there was no agreement between the direct employer and the special employer that the special employer would be liable for the payment of such compensation holding that an employer who commits an intentional tort against his employee cannot claim that the act was accidental so that workers compensation is the employees exclusive remedy holding that once the workers compensation act provides a remedy it is exclusive and the employee has no right to bring an action in commonlaw negligence against his employer