Caramagno v. Tuchel

433 N.W.2d 389, 173 Mich. App. 167
CourtMichigan Court of Appeals
DecidedNovember 21, 1988
DocketDocket No. 101255
StatusPublished

This text of 433 N.W.2d 389 (Caramagno v. Tuchel) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caramagno v. Tuchel, 433 N.W.2d 389, 173 Mich. App. 167 (Mich. Ct. App. 1988).

Opinions

Hood, J.

Plaintiff appeals as of right from an order of the Wayne Circuit Court granting summary disposition to defendant Lee Realty Company pursuant to MCR 2.116(0(10). The trial court held that a real estate salesperson is, as a matter of law, an independent contractor and that an employing real estate broker therefore can not be held liable for the salesperson’s negligence. We reverse.

The underlying facts in this case are not in dispute. Michael Caramagno was a passenger in the back seat of a vehicle being driven by defendant Tuchel when it was struck by a vehicle owned and operated by defendant Charlotte Bryant. Michael was seriously injured. Bryant was a licensed real estate salesperson who, at the time of the accident, was on official business for defendant Lee Realty, traveling from the realty office in Roseville, Michigan to a residence which was to be listed for sale through Lee Realty. Plaintiff filed a complaint against Tuchel, Carl Motor Sales, which [169]*169was the owner of the Tuchel vehicle, Bryant, Lee Realty, and the City of Detroit. A consent judgment in the amount of $20,000 was subsequently entered against Tuchel and Carl Motor Sales. Lee Realty then filed a motion for summary disposition under MCR 2.116(0(10), arguing that Bryant was an independent contractor and that Lee Realty therefore could not be vicariously liable. The trial court agreed, opining, "I do see the real estate salesperson as an independent contractor.”

A motion for summary disposition pursuant to MCR 2.116(0(10) asserts that no genuine issue of material fact exists and that the moving party is entitled to judgment as a matter of law. Samhoun v Greenfield Construction Co, Inc, 163 Mich App 34, 39-40; 413 NW2d 723 (1987).

In this case, there is no dispute as to the fact that defendant Bryant is a real estate salesperson who was working for defendant Lee Realty. Thus the only question, in this matter of first impression, is whether defendant Bryant was a servant or an independent contractor of defendant Lee Realty. If she was an independent contractor, her employer, Lee Realty, is not liable for her torts because, as a general rule, an employer of an independent contractor is not liable for the negligence of the contractor or the contractor’s employees. Bosak v Hutchinson, 422 Mich 712, 724; 375 NW2d 333 (1985), reh den 424 Mich 1201 (1985).

Our Supreme Court has defined an independent contractor as follows:

"An independent contractor is one who, carrying on an independent business, contracts to do a piece of work according to his own methods, and without being subject to the control of his employer as to the means by which the result is to be accomplished, but only as to the result of the work. [170]*170Generally, the circumstances which go to show one to be an independent contractor, while separately they may not be conclusive, are the independent nature of his business, the existence of a contract for the performance of a specified piece of work, the agreement to pay a fixed price for the work, the employment of assistants by the employee who are under his control, the furnishing by him of the necessary materials, and his right to control the work while it is in progress except as to results.” [Marchand v Russell, 257 Mich 96, 100-101; 241 NW 209 (1932), citing Zoltowski v Ternes Coal & Lumber Co, 214 Mich 231, 233; 183 NW 11 (1921), and 26 Cyc p 1546.]

In Marehand, the Court stated that the right to control,1 even if not exercised, was decisive in determining that the defendant was a servant rather than an independent contractor. Marehand, supra at 102. The Court also noted that the determination of whether the defendant was a servant or independent contractor was dependent on the facts. Marehand, supra at 103. In Holloway v Nassar, 276 Mich 212; 267 NW 619 (1936), the Court stated that no issue of fact was raised, but the Court reversed the jury’s decision that the individual defendant was a servant of the employer. The reason for reversal was that the plaintiff had "failed to sustain the burden of evidence that Nassar was a servant of defendant company at the time of the collision.” Holloway, supra at 217.

In both Marehand and Holloway, the individual defendants were traveling salesmen involved in auto collisions, and the issues were whether they [171]*171were independent contractors so as to release their employers of vicarious liability. In each case, the Court determined the relationship as a matter of law. In Sliter v Cobb, 388 Mich 202; 200 NW2d 67 (1972), also a case involving alleged vicarious liability of a master, the Court held that summary disposition was improper because the plaintiffs had raised an issue of fact as to whether the defendant was an employee (servant) of his employer or an independent contractor; the Court remanded for a new trial.

In this case, on the other hand, the evidentiary facts are undisputed. We conclude that, because of the statute which regulates, inter alia, real estate brokers and salespersons, those evidentiary facts are also susceptible of only one inference, that defendant Bryant, as a real estate salesperson, is a servant of defendant Lee Realty and not an independent contractor.

The governing statute is the Occupational Code, MCL 339.101 et seq.; MSA 18.425(101) et seq. The statute states that all real estate salespersons must be licensed, that only one license is issued for any given period, and that salespersons’ licenses must be held by a broker.

The statute distinguishes a real estate broker, defined as "an individual . . . who . . . sells . . .,” from a real estate salesperson, defined as "a person who ... is employed either directly or indirectly by a licensed real estate broker to sell . . . .” MCL 339.2501(a), (b); MSA 18.425(2501)(a), (b). Whereas a real estate salesperson must have forty hours of instruction, a real estate broker is required to have an additional ninety hours. MCL 339.2504; MSA 18.425(2504). A real estate salesperson applies for a license through a broker, and the broker holds that license as follows:

[172]*172(4) An applicant for a salesperson’s license shall set forth the period of time during which the applicant has been engaged in the business, stating the name of the applicant’s last employer and the name and the place of business of the individual, partnership, association, or corporation then employing the applicant or in whose employ the applicant is to enter. The application shall be accompanied by a written statement by the real estate broker in whose employ the applicant is to enter stating that in the real estate broker’s opinion the applicant is of good moral character, and recommending that the license be granted to the applicant. [MCL 339.2505(4); MSA 18.425(2505X4).]
Sec. 2506. The department shall issue to each person who meets the requirements of this article and who pays the appropriate license fee prescribed in section 37 of Act No. 152 of the Public Acts of 1979, a license in a form and size as prescribed by the department. This license shall show the name and address of the licensee and in case of a real estate salesperson’s license, shall show the name of the real estate broker by whom the real estate salesperson is employed. A license shall contain data prescribed by the department.

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Related

Nichol v. Billot
279 N.W.2d 761 (Michigan Supreme Court, 1979)
Sliter v. Cobb
200 N.W.2d 67 (Michigan Supreme Court, 1972)
Noble v. Roadway Express, Inc
394 N.W.2d 128 (Michigan Court of Appeals, 1986)
Samhoun v. Greenfield Construction Co., Inc.
413 N.W.2d 723 (Michigan Court of Appeals, 1987)
Bosak v. Hutchinson
375 N.W.2d 333 (Michigan Supreme Court, 1985)
Edwards v. Verploegh
396 N.W.2d 521 (Michigan Court of Appeals, 1986)
Michigan National Bank-Oakland v. Wheeling
419 N.W.2d 746 (Michigan Court of Appeals, 1988)
Marchand v. Russell
241 N.W. 209 (Michigan Supreme Court, 1932)
Holloway v. Nassar
267 N.W. 619 (Michigan Supreme Court, 1936)
Zoltowski v. Ternes Coal & Lumber Co.
183 N.W. 11 (Michigan Supreme Court, 1921)
Bosak v. Hutchinson
424 Mich. 1201 (Michigan Supreme Court, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
433 N.W.2d 389, 173 Mich. App. 167, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caramagno-v-tuchel-michctapp-1988.