Bayly v. Red House Motors d/b/a Bayly's Garage

CourtSuperior Court of Delaware
DecidedMay 6, 2025
DocketS24A-05-002 CAK
StatusPublished

This text of Bayly v. Red House Motors d/b/a Bayly's Garage (Bayly v. Red House Motors d/b/a Bayly's Garage) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bayly v. Red House Motors d/b/a Bayly's Garage, (Del. Ct. App. 2025).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

ROBERT BAYLY, : Claimant Below-Appellant, : C. A. No. S24A-05-002 CAK v. : On Appeal from Industrial : Accident Board Decision dated April 30, : 2024, IAB No. 1513116

RED HOUSE MOTORS, : d/b/a BAYLY’S GARAGE, :

Employer Below-Appellee. :

Submitted: April 8, 2025 Decided: May 6, 2025

On Appeal from the Industrial Accident Board

REVERSED

MEMORANDUM OPINION AND ORDER

Elissa A. Greenberg, Esquire, Elzufon Austin & Mondell, PA, 300 Delaware Avenue, Suite 1700, Wilmington, DE 19801, Attorney for Claimant-Appellant.

Geoffrey S. Lockyer, Esquire, Tybout, Redfearn & Pell, 501 Carr Road, Suite 300, Wilmington, DE 19899, Attorney for Employer/Carrier-Appellee.

KARSNITZ, R.J. PROCEDURAL BACKGROUND

This is an appeal from a decision dated April 30, 2024 (the “Decision”) of the

Delaware Industrial Accident Board (the “Board”), which dismissed a Petition to

Determine Compensation Due dated April 3, 2023 (the “Petition”) filed by Claimant-

Below, Robert Bayly (“Appellant”) after accepting a claim made by Federated

Reserve Insurance Company (“Carrier”) that Appellant was not covered under a

workers’ compensation policy issued by Carrier to Employer-Below, Red House

Motors, d/b/a Bayly’s Garage (“Employer”). (Either Carrier or Employer may be

referred to herein as “Appellee”).

Appellant filed the Petition seeking compensation under the Delaware

Workers’ Compensation Act (the “WCA”) for injuries sustained during a workplace

assault. On October 2, 2023, Carrier filed a Motion to Dismiss the Petition (the

“Motion to Dismiss”) on the grounds that Appellant was precluded from receiving

benefits for his injuries as a sole proprietor because he did not elect coverage for

himself.1 Litigation before the Board was bifurcated to address the coverage issue

apart from the merits. Both parties presented their full evidence on the coverage issue

at a Board hearing held on April 24, 2024. In its Decision, the Board granted the

Motion to Dismiss. On May 28, 2024, Appellant timely appealed the Decision to

this Court.

1 Under 19 Del. C. § 2308(b) and 19 Del. C. § 2306(b), both as discussed more fully herein. 2 On November 26, 2024, Appellant filed his Opening Brief. On February 6,

2025, Appellee filed its Answering Brief. On February 21, 2025, Appellant filed his

Reply Brief. I held oral argument on April 8, 2025. This is my decision on appeal.

FACTS

Appellant is the sole proprietor of Employer. On June 16, 2021, while

working at Employer, Appellant was assaulted by a temporary employee. He

sustained serious injuries including, but not limited to, the loss of eyesight in his left

eye, a broken jaw, a fractured rib, neck injuries, and facial numbness.

There is no factual dispute that, at the time of the work accident, Employer

was insured under a workers’ compensation policy issued by Carrier covering

workplace injuries of Appellant’s employees (“Employees”). The workers’

compensation policy covering Employer was part of a comprehensive insurance

package which Appellant purchased from Carrier in 2008. The insurance package

automatically renewed each year including, inter alia, the workers’ compensation

policy covering Employer. Carrier sent audit forms annually to Appellant so that

Carrier could adjust the amount of Appellant’s premiums for the policies in the

package. The audit forms properly identified Appellant as a sole proprietor but

instructed him to regard himself as an Employee. The audit forms also asked for all

Employees’ gross salaries. Appellant’s accountant provided the requested financial

information for the audit to Carrier. Appellant’s wife was a salaried Employee of

3 Employer, but Appellant was not.2 As a sole proprietor, he took draws against the

business instead of a salary.3 Therefore, the audit forms’ instructions did not request

inclusion of Appellant’s income.

Carrier was aware of Appellant's sole proprietor status when the package of

policies was purchased. Nowhere in the insurance policies or in the annual audits did

Carrier inform Appellant that he was uninsured for workers’ compensation benefits

for his own workplace injuries.

Since initiating his policies with Carrier in 2008, Appellant had never filed a

workers’ compensation claim until the accident in question. The only prior claim

involved property damage to his building. When Appellant reported his work

accident to Carrier, Carrier informed him that he was not covered, issued him a

partial refund for his workers’ compensation premiums in the amount of $3,085.96,

and cancelled his workers’ compensation policy.

THE BOARD HEARING

The dispute in this case stems from Carrier’s claim that coverage under the

Employer’s workers’ compensation insurance policy did not extend to Appellant as

the sole proprietor of Employer. Carrier argued at the Board hearing that that

Appellant, as a sole proprietor, failed to elect workers’ coverage for himself under 19

2 Transcript of the April 24, 2024, Board Hearing, at 47, 54-57. 3 Id. 4 Del. C. § 2308(b). Carrier stated that, if a sole proprietor wants to be covered under

his business’ workers’ compensation policy, he does not have to purchase an

additional workers’ compensation policy. However, Carrier’s internal procedure for

extending coverage to a sole proprietor requires the sole proprietor to (1) inform his

authorized insurance agent that he affirmatively elects coverage, and (2) complete a

prescribed form. In this case, argued Carrier, nothing in the record indicated that

Appellant had informed it of an election for coverage, and there was no election form

in the record completed by Appellant.

Carrier relied on the testimony of its insurance analyst that Appellant never

elected coverage for himself as sole proprietor. The analyst did not see any written

documentation in the file about Appellant’s workers’ compensation coverage

expectations. But he confirmed that, to ensure personal coverage, Appellant had to

inform his agent that he wished to be covered and complete a form required by the

Delaware Compensation Rating Bureau (“DCRB”). The analyst said it was Carrier’s

responsibility to send Appellant this form.

Appellant testified that he expressly told an authorized insurance agent of

Carrier that he wanted such personal coverage for himself as sole proprietor. In

selecting the insurance policies, Appellant stated that he relied on information and

representations made by an insurance agent authorized by Carrier to sell its insurance

products. However, the whereabouts of that particular agent are now unknown, and

5 he was unavailable to provide testimony or other evidence at the Board hearing. The

Board found as a matter of fact that Appellant did not elect coverage.

Carrier sold Appellant an Executive Professional Liability (“EPL”)

insurance policy (the “EPL”). The EPL was contained in Appellant’s insurance

package which contained multiple policies, including the workers’ compensation

policy. Appellant testified that he thought the EPL provided the personal/sole

proprietor workers’ compensation coverage he had requested. However, if strictly

construed as written, the EPL only covered Appellant in the event of kidnapping,

invasion of property, carjacking, or child abduction. These are very limited

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Bayly v. Red House Motors d/b/a Bayly's Garage, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bayly-v-red-house-motors-dba-baylys-garage-delsuperct-2025.