Commonwealth v. Great Lakes Television Co.

39 Pa. D. & C.2d 399, 1966 Pa. Dist. & Cnty. Dec. LEXIS 315
CourtPennsylvania Court of Common Pleas, Dauphin County
DecidedMarch 30, 1966
Docketno. 300
StatusPublished

This text of 39 Pa. D. & C.2d 399 (Commonwealth v. Great Lakes Television Co.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Dauphin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Great Lakes Television Co., 39 Pa. D. & C.2d 399, 1966 Pa. Dist. & Cnty. Dec. LEXIS 315 (Pa. Super. Ct. 1966).

Opinion

Lipsitt, J.,

The Bureau of Employment Security, Department of Labor and Industry, Commonwealth of Pennsylvania (hereinafter called “Department”) made an assessment against Great Lakes Television Company, which is engaged in the business of television broadcasting, for failure to include in its periodic reports, as required by the Pennsylvania Unemployment Compensation Law, Act of December 5, 1936, P. L. (1937) 2897, as amended, et seq., 43 PS §751, et seq., “wages” paid to individuals as “talent fees” for four quarters of 1962 and two quarters of 1963.

A petition for reassessment was filed by Great Lakes Television Company (hereinafter called “petitioner”) wherein it was denied that claimant, Mary Mainzer Greco, was an “employee”, and that payment for her services was subject to the Unemployment Compensation Law. A hearing was held on July 15, 1964. An order dated April 14, 1965, by the department, determined that petitioner was an “employer” of Mary Mainzer Greco and others, that the talent artists involved were “in employment”, and that the remuneration received was “wages” within the meaning of the said Pennsylvania Unemployment Compensation Law.

This proceeding is an appeal from the decision of the department. The reassessment petition and the specific facts in the testimony at the hearing relate only to Mary Mainzer Greco (hereinafter called “claimant”). Included in the assessment were seven other persons whose relation to petitioner was similar to claimant’s. These persons and the nature of their [401]*401services were referred to generally in the testimony, and the order of the department held petitioner liable for contributions for Mary Mainzer Greco and these others.

The only issue involved is whether individuals known as talent artists performed services “in employment” for “wages” for petitioner within the intent and meaning of the said law.

Mrs. Greco, according to the testimony at the reassessment hearing, entered into a relationship with petitioner when she won a contest to perform as a weather girl for a sponsored program. She subsequently did various commercials both for the company sponsoring the weather program and for another company. Except for a written agreement to participate in the contest and receive a minimum weekly salary, if selected, there was no formal contract signed, but there was an agreement reached for an amount of pay, the time involved and the type of job to be performed. The rate of her compensation could not be less than that called for by the union contract, but could be higher, depending upon the ability of claimant. The payments were made without deductions of any sort and were made by checks drawn on the general account of petitioner, rather than on the payroll account. The union contract excluded talent artists from the definition of employes.

The work performed by claimant was at petitioner’s studio, at a time set by petitioner and its clients, and the equipment of the station was used. The props for the program were furnished by the station as well as the make-up facilities. The direction to claimant, as well as others classified as talent artists, was given by petitioner. In the Greco case, the program had no script, but for the others the program script was furnished by the television company or sponsor.

Mrs. Greco testified that she had no previous tele[402]*402vision experience before working for this station and had no other employment in the television industry during the time involved. She said that she received about 10 hours of training or instruction prior to her appearance as the weather girl. During the year 1962, she had other employment. She married the weather man in October of 1962, and after her marriage, restricted her employment to petitioner’s station. She was replaced on the weather program after May 31, 1963, but continued to do commercials for another sponsor until July of that year.

The pertinent statutory provisions of the said Unemployment Compensation Law are:

1. Section 4 (1) (1), 43 PS §753, which provides that “ ‘Employment’ means all personal service performed for remuneration by an individual under any contract of hire, express or implied, written or oral, including service in interstate commerce, and service as an officer of a corporation”.

2. Section 4(1) (2) (B), which provides in part that “Services performed by an individual for wages shall be deemed to be employment subject to this act, unless and until it is shown to the satisfaction of the department that — (a) such individual has been and will continue to be free from control or direction over the performance of such services both under his contract of service and in fact; and (b) as to such services such individual is customarily engaged in an independently established trade, occupation, profession or business”.

As in many other cases of this kind, to meet the exclusionary requisites of the statute, there must be a factual determination of the extent and character of control and whether the activities are ordinarily engaged in by a person considered independent, or whether the services are ordinarily done within the framework of an employer-employe relationship. See Bureau of Employment Security v. AAA Moving and [403]*403Storage Company, 24 D. & C. 2d 494, 76 Dauph. 335 (1961); Department of Labor and Industry v. Research, Inc., 68 Dauph. 267 (1955); Vaughan v. Warner, 157 F. 2d 26 (1946); Schmidt v. Ewing, 108 F. Supp. 505 (1952). To decide if individuals characterized as talent artists, or, in some parts of the testimony, as free-lancers, are ordinarily engaged in or considered to be an independent occupation or business would be extremely difficult, as there is no established meaning for this occupational designation. The basic question here is whether control of the services existed in the artist or the television company as an ultimate fact. No Pennsylvania cases have been found which are directly in point, so the decision must be made on certain general principles.

The usual terminology is to describe a person under control of another as an employe and one free of control as an independent contractor. The Pennsylvania Superior Court has stated that the test in determining whether a workman is an employe of a person who engaged him is whether he is subject to the latter’s control or right of control, not only with regard to the work to be done, but also with regard to the manner of performing it, and it is not the fact of actual interference or exercise of control by the employer, but the existence of the right or authority to interfere or control which renders one an employe rather than an independent contractor: Eggelton v. Leete, 186 Pa. Superior Ct. 542 (1958).

The Commonwealth here argues that petitioner had the authority and right to control the manner in which the artist performed her job. Petitioner asserts that claimant was free of control and direction over the performance of her services. It contends that several factors show as a matter of fact that claimant was an independent contractor. It points out there were no demands on the time of claimant, except that she be [404]*404prepared to do her show or commercial at the proper time; that her method of presentation was to be developed as she saw fit; that she was free to do similar services on other television stations and that she was responsible for obtaining and organizing the material which she presented on the weather girl show.

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Related

Eggelton v. LEETE
142 A.2d 777 (Superior Court of Pennsylvania, 1958)
Rodgers v. P-G Publishing Co.
166 A.2d 544 (Superior Court of Pennsylvania, 1960)
Vaughan v. Warner
157 F.2d 26 (Third Circuit, 1946)
Schmidt v. Ewing
108 F. Supp. 505 (M.D. Pennsylvania, 1952)

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Bluebook (online)
39 Pa. D. & C.2d 399, 1966 Pa. Dist. & Cnty. Dec. LEXIS 315, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-great-lakes-television-co-pactcompldauphi-1966.