DEXTER WEBSTER v. ERIC CAMPBELL

CourtCourt of Appeals of Georgia
DecidedJune 13, 2025
DocketA25A0319
StatusPublished

This text of DEXTER WEBSTER v. ERIC CAMPBELL (DEXTER WEBSTER v. ERIC CAMPBELL) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DEXTER WEBSTER v. ERIC CAMPBELL, (Ga. Ct. App. 2025).

Opinion

SECOND DIVISION DOYLE, P. J., RICKMAN, P. J. and GOBEIL, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 13, 2025

In the Court of Appeals of Georgia A25A0319. WEBSTER v. CAMPBELL et al.

DOYLE, Presiding Judge.

This case arises from the trial court’s grant of summary judgment to Eric

Campbell and Hansen & Adkins Auto Transport, Inc. (“Hansen”) (collectively, “the

Defendants”), regarding injuries Dexter Webster allegedly sustained in a car accident

negligently caused by Campbell. The trial court determined that Webster’s claims

were barred by the exclusive remedy provision of the Georgia Workers’

Compensation Act (“WCA”). Webster now appeals from that order, arguing, in two

related enumerations of error, that the trial court erred by concluding that he was

Hansen’s employee, rather than an independent contractor. For the reasons that

follow, we affirm. “We review the grant of a motion for summary judgment de novo, viewing the

evidence, and all reasonable inferences drawn therefrom, in the light most favorable

to the nonmovant.”1

So viewed, the record reflects that in 2022, Webster was a passenger in a

vehicle driven by Campbell that struck another vehicle. At the time of the accident,

Campbell and Webster both worked for Hansen, which owned the vehicle that

Campbell was driving. The accident occurred while Webster was working for Hansen

as a vehicle transporter.

In 2023, Webster sued Campbell for negligence related to the accident and later

amended his complaint to add Hansen as a party defendant based on a theory of

vicarious liability. In particular, Webster alleged the following in his amended

complaint: that Campbell and Webster were both employees of Hansen at the time of

the accident; that Hansen owned the vehicle Campbell was driving; and that Campbell

was acting within the scope of his employment when the accident occurred. In their

answers, the Defendants admitted the truth of each of these allegations. Moreover, in

1 (Punctuation omitted.) Odom v. Franklin, 368 Ga. App. 246, 246 (889 SE2d 405) (2023). See also York v. Moore, 367 Ga. App. 152, 154 (1) (885 SE2d 193) (2023) (“[S]ummary judgment is proper if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law.”) (punctuation omitted). 2 Webster’s verified responses to the Defendants’ interrogatories, he listed Hansen as

his employer from 2016 to 2022 and indicated that he “was working in the course and

scope of his employment at the time o[f] the incident at Hansen . . . as an [a]uto

transporter.”

The Defendants moved for judgment on the pleadings or, alternatively, for

summary judgment, arguing that the WCA’s exclusive remedy provision barred

Webster’s lawsuit to the extent that the accident occurred during the course and

scope of his employment with Hansen. In his response to the motion, Webster

disclaimed his status as an employee of Hansen, asserting instead that he was an

independent contractor at the time of the accident. In support of this assertion,

Webster produced a document purporting to be a 2017 independent contractor

agreement between him and Hansen.2 The document refers to Webster as a

contractor, provides that a contractor is not an employee of the company, and requires

Webster to maintain his own insurance. The document also states that “[t]he

independent contractor relationship shall be for all purposes, including workmen’s

compensation as allowed and by the applicable state worker’s compensation laws of

2 Although the document does not bear Webster’s full signature, it was signed by Hansen, and Webster initialed each page of the document, including the signature page. 3 the state of domicile . . . .” Webster also produced documents purporting to be

summaries of payments from Hansen to Webster from 2022 that were labeled as

independent contractor settlement summaries.3

The trial court granted the Defendants’ summary judgment motion. In its

order, the trial court found that Webster had claimed to be an employee of Hansen in

his amended complaint and that Webster’s interrogatory responses identified Hansen

as his employer from 2016 to 2022. Additionally, the trial court found that Webster

had specifically admitted in his interrogatory responses that he was working in the

course and scope of his employment with Hansen as a vehicle transporter at the time

of the accident. The trial court concluded that because the purported independent

contractor agreement lacked Webster’s signature and was not otherwise

authenticated, it could not constitute admissible evidence sufficient to create a jury

issue as to whether Webster was an employee or independent contractor at the time

of the accident.4 Nevertheless, the trial court noted the conflict between the purported

agreement and Webster’s representations in his pleadings and discovery responses

3 Neither the purported independent contractor agreement nor settlement summaries were authenticated by affidavit or other sworn testimony. 4 The trial court’s order did not rule on the admissibility or legal import of the purported independent contractor settlement summaries. 4 and resolved this conflict in the Defendants’ favor. Accordingly, the trial court

concluded that Webster was an employee of Hansen at the time of the accident and

that his lawsuit was thus barred by the WCA’s exclusive remedy provision.5 This

appeal followed.

In his two enumerations of error, Webster contends that the trial court erred (1)

by deeming the purported independent contractor agreement inappropriate for

consideration on summary judgment and (2) by ruling that any conflict between the

purported agreement and Webster’s pleadings and discovery responses should be

resolved against him. We discern no basis for reversal.

The Georgia WCA “provide[s] a complete and exclusive system and procedure

for the resolution of disputes between employers and employees . . . concerning

accidents and injuries arising out of and in the course of employment as defined by this

chapter.”6 Pursuant to the WCA’s exclusive remedy provision, “[t]he rights and

remedies granted to an employee by this chapter shall exclude and be in place of all

other rights and remedies of such employee[.]”7 In the event that “the [WCA]

5 OCGA § 34-9-11 (a). 6 OCGA § 34-9-23. 7 OCGA § 34-9-11 (a). 5 applies, the exclusive remedy provision not only prevents the injured employee from

bringing a tort claim against the employer, but also prevents a tort claim against any

co-employees of the same employer.”8

Whether the WCA’s exclusive remedy provision bars a lawsuit is a question of

law subject to de novo review.9 And we will affirm a trial court’s grant of summary

judgment “if it is correct for any reason, even if that reason is different than the reason

upon which the trial court relied.”10

1.

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DEXTER WEBSTER v. ERIC CAMPBELL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dexter-webster-v-eric-campbell-gactapp-2025.