PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 23-1163

PARKER O’NEIL WIDEMAN,

Plaintiff – Appellant,

v.

INNOVATIVE FIBERS LLC; STEIN FIBERS LTD,

Defendants – Appellees.

No. 23-1167

RILEY C. DRAPER,

Plaintiff – Appellant,

v.

INNOVATIVE FIBERS LLC; STEIN FIBERS LTD,

Defendants – Appellees.

No. 23-1169

WILLIAM F. DOUGLASS; JESSICA L. DOUGLASS,

Plaintiffs – Appellants,

v. USCA4 Appeal: 23-1167 Doc: 86 Filed: 05/02/2024 Pg: 2 of 14

INNOVATIVE FIBERS LLC; STEIN FIBERS LTD,

Defendants – Appellees.

Appeals from the United States District Court for the District of South Carolina, at Spartanburg. Judge Donald C. Coggins, Jr., District Judge. (7:22-cv-00418-DCC; 7:22- cv-00419-DCC; 7:22-cv-00420-DCC)

Argued: January 23, 2024 Decided: May 2, 2024

Before DIAZ, Chief Judge, and NIEMEYER and RICHARDSON, Circuit Judges.

Vacated and remanded by published opinion. Judge Richardson wrote the opinion, in which Chief Judge Diaz and Judge Niemeyer joined.

ARGUED: Bert Glenn Utsey, III, CLAWSON FARGNOLI UTSEY, LLC, Charleston, South Carolina, for Appellants. Hamlet Sam Mabry, III, HAYNSWORTH SINKLER BOYD, PA, Greenville, South Carolina, for Appellees. ON BRIEF: Samuel R. Clawson, Jr., Christina Rae Fargnoli, CLAWSON FARGNOLI UTSEY, LLC, Charleston, South Carolina; Charles T. Slaughter, MORGAN LITIGATION GROUP, LLC, Lexington, South Carolina, for Appellants. Patrick H. Allan, LEE LAW OFFICES, Spartanburg, South Carolina, for Appellants. Riley C. Draper, William F. Douglass, and Jessica L. Douglass. Jonathan D. Klett, HAYNSWORTH SINKLER BOYD, P.A., Greenville, South Carolina; Kevin Lindsay Terrell, THE WARD FIRM PA, Spartanburg, South Carolina, for Appellees.

2 USCA4 Appeal: 23-1167 Doc: 86 Filed: 05/02/2024 Pg: 3 of 14

RICHARDSON, Circuit Judge:

South Carolina law provides that certain workers’ compensation disputes are within

the exclusive cognizance of the state Workers’ Compensation Commission. This means

that covered employees cannot bring common-law actions, like tort claims, in state courts.

But state law cannot circumscribe federal subject matter jurisdiction. So when these

injured workers arrived in federal court and were met with a motion to dismiss for lack of

subject matter jurisdiction, which cited the state law, a procedural mess ensued. Despite

the understandable confusion about the state law’s effect on federal jurisdiction, we

conclude that the district court erred in dismissing the workers’ complaint for lack of

subject matter jurisdiction. We thus vacate that decision and remand for further

proceedings.

I. Background

A. Calamity at the Spartanburg Plant

Innovative Fibers LLC and Stein Fibers Ltd. (together, “Defendants”) owned and

operated a plant in Spartanburg, South Carolina. That plant converted recycled plastics

into polyester fibers. In June 2020, to dry the plastic material, Defendants installed two

large, natural-gas-fueled ovens (sometimes called “crystallizers”) in a 33-foot-tall

chamber. Each oven was encased in a steel scaffolding “superstructure” that supported

two platforms above the oven, providing access for mainte

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