Emerson Dennis Saul v. Seaboard Triumph Foods, L.L.C.

CourtCourt of Appeals of Iowa
DecidedMay 8, 2024
Docket23-0402
StatusPublished

This text of Emerson Dennis Saul v. Seaboard Triumph Foods, L.L.C. (Emerson Dennis Saul v. Seaboard Triumph Foods, L.L.C.) is published on Counsel Stack Legal Research, covering Court of Appeals of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emerson Dennis Saul v. Seaboard Triumph Foods, L.L.C., (iowactapp 2024).

Opinion

IN THE COURT OF APPEALS OF IOWA

No. 23-0402 Filed May 8, 2024

EMERSON DENNIS SAUL, Plaintiff-Appellant,

vs.

SEABOARD TRIUMPH FOODS, L.L.C., Defendant-Appellee. ________________________________________________________________

Appeal from the Iowa District Court for Woodbury County, Roger L. Sailer,

Judge.

A plaintiff appeals from the district court’s grant of summary judgment

dismissing his negligence claim. REVERSED AND REMANDED.

Christopher P. Welsh of Welsh & Welsh, PC, LLO, Omaha, Nebraska, for

appellant.

Sarah K. Kleber and Jeff W. Wright of Heidman Law Firm, P.L.L.C., Sioux

City, for appellee.

Heard by Bower, C.J., and Badding and Langholz, JJ. 2

LANGHOLZ, Judge.

As a part of the “grand bargain” underlying Iowa’s workers’ compensation

system, in exchange for the simplified process of receiving compensation for their

workplace injuries, injured workers give up the right to sue their employers over

those injuries. Loew v. Menard, Inc., 2 N.W.3d 880, 883 (Iowa 2024); see also

Iowa Code § 85.20(1) (2020). But when workers employed by a temporary staffing

agency are injured at their assigned worksite, the question arises whether the

company they are assigned to work for—the staffing agency’s customer—is also

their employer. Our supreme court has held that this is a fact question—resolved

case-by-case, based on whether the worker and the customer “entered into a

contract of hire, express or implied.” Parson v. Procter & Gamble Mfg. Co., 514

N.W.2d 891, 893 (Iowa 1994). And when no express contract exists between the

two, both the worker and the customer must have intended to establish an

employment relationship to find an implied contract. See id. at 894–95.

Here, the customer—Seaboard Triumph Foods, L.L.C.—presented strong

evidence supporting its motion for summary judgment from which a factfinder could

conclude that it was a second employer of the injured worker—Emerson Saul. But

we cannot say as a matter of law that this is the only reasonable conclusion a

factfinder could reach from the evidence. For starters, Seaboard Triumph’s human

resources manager testified that Saul was not Seaboard Triumph’s employee.

And some provisions in the contract between Seaboard Triumph and the staffing

agency could support an inference that Seaboard Triumph did not intend to

establish an employment relationship. The district court thus erred in granting

summary judgment. We reverse and remand for further proceedings. 3

I.

In 2017, Seaboard Triumph opened a new pork processing plant in Sioux

City, Iowa. To meet its labor needs as it ramped up and tried to increase its own

workforce, it contracted with a temporary staffing agency to recruit and provide

temporary employees at the plant.

The Staffing Contract. Under Seaboard Triumph’s contract with the staffing

agency, the agency agreed “to provide temporary employees (each a [staffing

agency] Employee[]) to” Seaboard Triumph. Indeed, the contract repeatedly refers

to a temporary employee as the staffing agency’s employee throughout the

contract. And unless the temporary employee has worked at least 600 hours in a

year, the contract requires Seaboard Triumph “to pay a referral fee” of up to “20%

of the first year wages of any [staffing agency] Employee who is hired directly or

indirectly (e.g., directed to sign on through another staffing agency) by [Seaboard

Triumph] within twelve (12) months after said [staffing agency] Employee’s last day

of work for [Seaboard Triumph] through [the staffing agency].”

The staffing agency handles weekly payroll and tax withholding; covers

mandatory insurance; and agrees to “maintain, and keep in force and effect during

the term of this Agreement and to the full extent required by law, workers’

compensation insurance and unemployment insurance.” Temporary employees

are paid time-and-a-half overtime and “[i]f [Seaboard Triumph] employees are paid

double time to work holidays, etc. [staffing agency] employees will be paid double

time also.” But according to deposition testimony of Seaboard Triumph’s human

resources manager, a temporary employee does not receive the same benefits of

employment as a directly hired employee because, “He was not our employee.” 4

The staffing contract itself does not include any provision expressly stating

that temporary employees are Seaboard Triumph employees or disclaiming that

employment relationship. But Seaboard Triumph agreed, in a section titled “Loss

and Damages While Working for Client,” that “the [staffing agency] Employees are

under [Seaboard Triumph’s] supervision while they are placed with [Seaboard

Triumph].” Seaboard Triumph would further “be responsible for any and all loss,

damage or injury caused by a [staffing agency] Employee, directly or indirectly,

while the [staffing agency] Employee is under the supervision of” Seaboard

Triumph. Seaboard Triumph also agreed to comply with various requirements

about the work environment, safety practices, and recording the temporary

employee’s hours worked.

“Upon approval and employment offer, [the staffing agency] will E-verify all

workers, conduct drug screens and background checks for all workers hired

through [the staffing agency] for Seaboard Triumph.” Other than this implicit

recognition of some “approval and employment offer” process, the contract does

not expressly address Seaboard Triumph’s rights to accept and terminate the

temporary workers. But its vice president of human resources swore in an affidavit

that Seaboard Triumph “was able to select referrals from [the staffing agency] as

needed and was not obligated to accept any person referred for work as a

temporary employee by” the staffing agency. Likewise, she said that Seaboard

Triumph “could discipline temporary employees and end their engagement at will

without [the staffing agency’s] input, permission or approval.”

Saul’s Hiring. In spring 2019, Saul approached the staffing agency about a

job. He spent a day watching safety videos at the staffing agency. And the staffing 5

agency assigned him a job at Seaboard Triumph, telling him that he should show

up at the plant the following Monday for a week of orientation—the same

orientation required of any Seaboard Triumph employee. The staffing agency did

not have employees at the plant to supervise the temporary employees. Rather,

Saul was supervised by Seaboard Triumph employees while working at the plant.

Except for different pay and benefits being provided by the staffing agency,

Saul was essentially treated the same as any other full-time employee at the plant.

He followed the same work rules, policies, and procedures that applied to other

employees. He was issued the same smocks, hard hats, and other personal

protective equipment that all employees used. He had the same identification card

and access to the same parking lots, locker rooms, break areas, health facilities,

and laundry facilities as other employees. He worked the same sorts of shifts and

was integrated fully into the production line with all other employees. And Saul

even joined the same union and got the same union card as other employees.

The Injury. A few months later—in July 2019—Saul’s ankle was injured

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Farris v. General Growth Development Corp.
354 N.W.2d 251 (Court of Appeals of Iowa, 1984)
Fletcher v. Apache Hose & Belting Co., Inc.
519 N.W.2d 839 (Court of Appeals of Iowa, 1994)
Henderson v. Jennie Edmundson Hospital
178 N.W.2d 429 (Supreme Court of Iowa, 1970)
Velazquez v. Hydro Conduit Corp.
715 N.W.2d 767 (Court of Appeals of Iowa, 2006)
Parson v. Procter & Gamble Manufacturing Co.
514 N.W.2d 891 (Supreme Court of Iowa, 1994)
Caterpillar Tractor Co. v. Shook
313 N.W.2d 503 (Supreme Court of Iowa, 1981)
Jones v. Sheller-Globe Corp.
487 N.W.2d 88 (Court of Appeals of Iowa, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
Emerson Dennis Saul v. Seaboard Triumph Foods, L.L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/emerson-dennis-saul-v-seaboard-triumph-foods-llc-iowactapp-2024.