El Paso Tool & Die Co., Inc. v. Carlos Mendez

Court of Appeals of Texas·Decided December 4, 2019·No. 08-19-00087-CV·Published

Opinion

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

EL PASO TOOL AND DIE § COMPANY, INC., No. 08-19-00087-CV Appellant, § Appeal from the v. § County Court at Law Number Three § CARLOS MENDEZ of El Paso County, Texas § Appellee. (TC# 2017-DCV0027) §

OPINION We granted El Paso Tool and Die Company, Inc. (El Paso Tool) the right to pursue a

permissive appeal from the denial of a motion for summary judgment. See TEX.CIV.PRAC. &

REM.CODE ANN. § 51.014(d) and (f) (authorizing and setting forth standards for permissive

appeals). The controlling legal issue that El Paso Tool advances is “[w]hether a general employee

of a temporary staffing agency may also be an employee of the staffing agency's client company

for purposes of the workers' compensation exclusive remedy provision.” The answer to that

question is undoubtedly “yes” under existing Texas Supreme Court precedent. But more

specifically, El Paso Tool contends that the trial court applied the wrong legal standard to answer

that question by looking to case law under the respondeat superior and borrowed servant doctrines,

rather than the standard developed under the Texas Labor Code for determining who is the

“employer” of an injured worker. On closer examination of the record, it is not clear to us that the

1 trial court in fact applied the wrong standard. Rather, it may have simply found a genuine issue

of material fact which precluded summary judgment. Accordingly, we conclude that the petition

for permissive review was improvidently granted and remand the case to the trial court.

I. BACKGROUND

Carlos Mendez lost all or parts of two fingers in an industrial accident on March 16, 2015.

According to the allegations in his lawsuit, he was employed by Elwood Staffing at the time of the

accident. He alleged that he was working as an independent contractor at El Paso Tool’s facility.

Specifically, he was working on a machine press that stamps out metal parts. When his hand was

in the working area of the machine, the stamping press unexpectedly came down and crushed

several of his fingers. His suit asserts common law negligence claims against El Paso Tool, and

product liability claims against the alleged manufacturer of the machine press. Only the claims

against El Paso Tool are before us.

El Paso Tool filed a motion for summary judgment, supported by the affidavit of its

President and sole shareholder, Salvador Robles. The affidavit claimed that Mendez was a

temporary laborer supplied to El Paso Tool under a contract with Elwood Staffing. His affidavit

stated that Mendez’s duties required him to operate metal press machines, and that he was injured

on one of those machines. The affidavit further claims that El Paso Tool was solely responsible

for scheduling hours, assigning work, and supervising Mendez’s daily activities. Robles also

averred that Mendez was: (1) supervised only by El Paso Tool, and not Elwood Staffing at the

time of the accident; (2) he was working at El Paso Tool’s facility; and (3) using a machine press

that it owned. Finally, the affidavit states that El Paso Tool had its own workers’ compensation

policy. From this, El Paso Tool urged that it was entitled to judgment as a matter law under the

2 exclusive remedy defense found in the Texas Labor Code. (hereinafter “the Act”)1 The motion

was based on El Paso Tool being a subscriber under the Act, and not that Elwood Staffing as a

temporary employment agency provided workers’ compensation insurance to all the employees

that it sent to client companies.2

Mendez’s response to the summary judgment alleged that El Paso Tool did not control the

specific details of his work at the time of his injury. Consequently, he asserted that he was not a

“borrowed servant” or an “employee” of El Paso Tool at the time of the accident. Alternatively,

he claimed that the evidence at least created a fact question on that issue. From the summary

judgment evidence, we gather that there was no signed contract between El Paso Tool and Elwood

Staffing, thus no written contractual term between those parties that defined Mendez’s

employment status. Rather, the parties relied only on affidavits and deposition testimony, either

from Mendez or El Paso Tool witnesses.

Mendez attached his own affidavit which states that no one from El Paso Tool “controlled

the specific details of the work I was performing at the time of the incident[.]” El Paso Tool had

indicated that Javier Berumen, Jr. was supervising Mendez’s work. Mendez’s affidavit, however,

states that Berumen did not “supervise my work in any way and was not even present when the

incident took place.” Other than showing him how to turn the machine press on or off, he swore

that no one from El Paso Tool trained him on how to do the job. Mendez also attached several

depositions to his response that we describe in more detail below.

1 TEX.LAB.CODE ANN. § 408.001(a) provides:

Recovery of workers' compensation benefits is the exclusive remedy of an employee covered by workers' compensation insurance coverage or a legal beneficiary against the employer or an agent or employee of the employer for the death of or a work-related injury sustained by the employee. 2 Contrast Robles v. Mt. Franklin Food, L.L.C., No. 08-18-00170-CV, 2019 WL 3812375, at *6 (Tex.App.--El Paso Aug. 14, 2019, reh’g pending).

3 The trial court denied El Paso Tool’s motion. Its order states: “The Court finds that

TEX.LAB.CODE ANN. § 408.001 does not apply to the facts in this case because [Mendez] was

working as an independent contractor and not an employee of [El Paso Tool] at the time of

[Mendez’s] accident.” The order further finds that an interlocutory appeal would materially

advance the ultimate termination of the lawsuit, and that the trial court’s ruling turned on a

controlling issue of law: whether the exclusive remedy defense under Section 408.001 “applies

under the facts in this case.” El Paso Tool then asked this Court for permission to appeal under

TEX.CIV.PRAC. & REM.CODE ANN. § 51.014(d) and (f) which we granted.

II. DISCUSSION

A. The Exclusive Remedy Defense and Temporary Workers.

As the Texas Supreme Court has observed, Texas has stood alone in not requiring private

employers to provide workers’ compensation insurance. Port Elevator-Brownsville v. Casados,

358 S.W.3d 238, 241 (Tex. 2012). Texas does, however, encourage private employers to secure

coverage by (1) abolishing many common-law defenses in work-injury lawsuits if they do not

subscribe, and (2) providing a bar to ordinary negligence suits if they do. TEX.LAB.CODE ANN.

§ 406.033 (abolishing common-law defenses); Id. at § 408.001(a) (codifying exclusive remedy

defense). Thus, an employer who subscribes to workers' compensation insurance may raise the

exclusive remedy provision as a bar to a negligence claim filed against it. Casados, 358 S.W.3d

at 241.3

To invoke the exclusive remedy provision, a defendant must generally show that: (1) the

injured worker was an employee of the defendant at the time of the work-related injury, and (2)

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