Maryland Court Finds Large Company Liable for Workers’ Compensation Benefits
Despite an independent contract, a Maryland appellate court determined that a large company was liable to a farm worker for workers’ compensation benefits, according to a decision by the Court of Special Appeals. To understand the significance of this decision, it will be necessary to examine relevant factual background, procedural history, and legal analysis.
Factual Background
In 2009, a worker (the “Farm Worker”) accepted a job to perform basic labor and maintenance tasks on an independently owned chicken farm. Later that year, the chicken farm owner contracted an illness and later died. Ownership of the farm passed to the original owner’s wife.
But the wife did not have experience raising chickens. As a result, representatives of a large chicken company (the “Chicken Producer”) taught the Farm Worker how to raise the animals and manage the farm. Representatives of the Chicken Producer were on site multiple times each week, providing guidance on all facets of farm operations. When the wife became sick, the Farm Worker moved his residence to the farm, as the Chicken Producer required 24/7 oversight.
In 2013, the wife sold the chicken farm to a new owner (the “Landowner”). The Landowner was also unfamiliar with raising chickens. So he entered into a contract with the Chicken Producer, making the company an “absentee owner.” The Chicken Producer agreed to the contract terms, but only if the Landowner retained the Farm Worker to manage farm operations.
In 2014, the Farm Worker contracted an occupational disease affecting his lungs. The Farm Worker claimed that the occupational disease developed as a result of his work activities at the chicken farm.
Procedural History
On June 27, 2014, the Farm Worker filed a workers’ compensation claim against the Landowner, requesting benefits for an occupational disease. As the Landowner did not have workers’ compensation insurance, the Uninsured Employers’ Fund (“UEF”) became part of the claim. Then the Landowner and UEF involved the Chicken Producer in the claim as well.
On March 3, 2016, the Workers’ Compensation Commission (“Commission”) conducted a hearing. The Commission determined that the Farm Worker contracted an occupational disease that arose out of employment. Furthermore, the Commission found that the Landowner and Chicken Producer were co-employers of the Farm Worker. The Chicken Producer contested this decision by filing an appeal with the Circuit Court.
On June 20, 2018, the jury trial in the Circuit Court concluded. The jury determined that the Farm Worker was not actually employed by the Chicken Producer when he contracted his occupational disease. Then the UEF challenged the jury decision and requested that the Court of Special Appeals review the case.
Legal Analysis
After considering arguments and evidence, the Court of Special Appeals reversed the decision of the Circuit Court. More specifically, the Court of Special Appeals determined that the Farm Worker was a de-facto employee of the Chicken Producer at the time of injury.
The rationale for this decision was that the Chicken Producer exercised a high degree of control over the conditions of the Farm Worker’s employment. By directing the day-to-day operations of the farm, the Chicken Producer essentially created an employment relationship with the Farm Worker — even though there was not a formal agreement in place between the Chicken Producer and Farm Worker.
Let Us Help You Today
If you need legal help with a workers’ compensation claim in Maryland, it can be extremely valuable to reach out to a trusted Baltimore workers’ compensation attorney. The attorneys at Iamele & Iamele, LLP in Baltimore, Maryland, feature numerous years of combined legal experience in matters of workers’ compensation. If you need legal help, contact us today for a free initial consultation.
Resource:
courts.state.md.us/data/opinions/cosa/2019/1057s18.pdf
