J-King v. Conley

CourtCourt of Appeals of Arizona
DecidedFebruary 27, 2025
Docket1 CA-IC 24-0025
StatusUnpublished

This text of J-King v. Conley (J-King v. Conley) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J-King v. Conley, (Ark. Ct. App. 2025).

Opinion

NOTICE: NOT FOR OFFICIAL PUBLICATION. UNDER ARIZONA RULE OF THE SUPREME COURT 111(c), THIS DECISION IS NOT PRECEDENTIAL AND MAY BE CITED ONLY AS AUTHORIZED BY RULE.

IN THE ARIZONA COURT OF APPEALS DIVISION ONE

J-KING EXCAVATING; ARIZONA VALLEY HOME BUILDERS, LLC d/b/a J-KING EXCAVATION; J-KING EXCAVATION, LLC d/b/a J- KING EXCAVATING; BOB MICHAEL ELLIS, Petitioner Employers,

v.

INDUSTRIAL COMMISION OF ARIZONA, Respondent,

AMBER CONLEY, Respondent Employee,

ICA SPECIAL FUND DIVISION/NO INSURANCE SECTION, Respondent Party in Interest.

No. 1 CA-IC 24-0025 FILED 02-27-2025

Special Action - Industrial Commission No. 20223550014 The Honorable Robert E. Trop, Administrative Law Judge

AFFIRMED

COUNSEL

Corl Law Practice PLLC, Chandler By Robert D. Corl Counsel for Petitioner Employer

Industrial Commission of Arizona, Phoenix By Afshan Peimani Counsel for Respondent ICA Snow Carpio Weekley PC, Phoenix By Brian A. Weekley Co-Counsel for Respondent Employee

Broening Oberg Woods & Wilson PC, Phoenix By Kelley M. Jancaitis Co-Counsel for Respondent Employee

Industrial Commission of Arizona, Phoenix By Scott J. Cooley Counsel for Respondent Party in Interest

MEMORANDUM DECISION

Presiding Judge Michael S. Catlett delivered the decision of the Court, in which Judge Daniel J. Kiley and Judge David D. Weinzweig joined.

C A T L E T T, Judge:

¶1 In this workers’ compensation case, J-King Excavation, LLC (“J-King”) argues the Administrative Law Judge (“ALJ”) erred in finding that Amber Conley (“Conley”) was an employee eligible for workers’ compensation benefits. Because the ALJ correctly concluded Conley was J- King’s employee, we affirm the award.

FACTS AND PROCEDURAL HISTORY

¶2 We view the evidence in the light most favorable to affirming the award. Lovitch v. Indus. Comm’n, 202 Ariz. 102, 105 ¶ 16 (App. 2002).

¶3 Bob Michael Ellis (“Ellis”) is the sole owner of J-King. In May 2022, Ellis interviewed and hired Conley to be a ground worker. Ellis instructed Conley on her responsibilities, which included watering the ground at excavation sites to control dust, picking up equipment or tools for other workers, and cleaning and fueling excavation equipment. Ellis provided Conley with a truck, company debit card, and the tools and equipment required for her job. J-King paid Conley per hour on a weekly basis without payroll or tax deductions.

¶4 In December 2022, Ellis asked Conley to clean a piece of grading equipment to prepare it for transport. Conley climbed on the

2 J-KING et al. v. CONLEY Decision of the Court

equipment to clean the back window and fell, sustaining injuries. Conley filed a workers’ compensation claim, which the Industrial Commission of Arizona (“ICA”) denied. Conley requested a hearing with an ALJ.

¶5 The ALJ held a hearing where Conley testified that she believed J-King was her employer and, as her boss, Ellis had the right to hire and fire her. Ellis testified J-King did not have any employees—only independent contractors. Ellis also testified Conley’s employment was “open-ended,” but the job on which she was injured was the last job he had for her.

¶6 Applying the control test, the ALJ found Conley and J-King had a regular, open-ended relationship, J-King provided Conley with equipment necessary to perform her job, Ellis assigned and instructed Conley on what tasks to perform, J-King paid Conley per hour on a weekly basis, and Conley used a J-King debit card for supplies. The ALJ also noted a lack of evidence that Conley worked as an independent contractor on a regular basis for any other company during the time she worked for J-King. Finally, the ALJ found Conley’s cleaning and dust control duties were not incidental to J-King’s business operations because J-King was legally required to control dust at its excavation sites and clean equipment to prevent debris from falling off during transport. The ALJ concluded Conley’s injury arose out of and during an employer-employee relationship with J-King and therefore found Conley’s claim compensable. At J-King’s request, the ALJ issued a decision upon review and affirmed the award.

¶7 J-King sought special action review. We have jurisdiction. See A.R.S. §§ 12-120.21(A)(2), 23-951(A); Ariz. R.P. Spec. Act. 21.

DISCUSSION

¶8 J-King argues the ALJ made factual errors in applying A.R.S. § 23-902 and the control test and concluding that Conley was an employee, not an independent contractor. Whether a worker was an employee is a mixed question of law and fact. We defer to the ALJ’s factual findings underlying its determination that a worker was an employee. Danial v. Indus. Comm’n, 246 Ariz. 81, 83 ¶ 11 (App. 2019). But whether the factual findings adequately support that the worker was an employee is a question of law we review de novo. Id.

¶9 To start, we reject J-King’s argument that the ALJ made factual errors in applying § 23-902 and the control test. J-King argues the ALJ ignored testimony proving Conley was an independent contractor. To the contrary, the ALJ’s decisions thoroughly and accurately summarized

3 J-KING et al. v. CONLEY Decision of the Court

the testimony and evidence. The ALJ did not ignore testimony but instead found certain testimony more credible—a determination it was entitled to make as “the sole judge of witness credibility.” Holding v. Indus. Comm’n, 139 Ariz. 548, 551 (1984). Because those credibility determinations were reasonable, we will not disturb them. See Henderson-Jones v. Indus. Comm’n, 233 Ariz. 188, 191–92 ¶ 9 (App. 2013) (“[T]he ALJ is at liberty to choose whichever [indicia] he or she finds most credible, and this court will not disturb the ALJ’s conclusion unless it is wholly unreasonable.”).

¶10 Under Arizona workers’ compensation laws, only employees injured in the course of employment are eligible for compensation. Danial, 246 Ariz. at 83 ¶ 12. An “employee” is a worker “over whose work the employer retains supervision or control, and the work is a part or process in the trade or business of the employer[.]” A.R.S. § 23-902(B). An independent contractor, on the other hand, is not eligible for workers’ compensation. An independent contractor is a worker who is “not subject to the rule or control of the business for which the work is done, but is engaged only in the performance of a definite job or piece or work, and is subordinate to that business only in effecting a result in accordance with that business design[.]” A.R.S. § 23-902(C).

¶11 In workers’ compensation cases, we apply the control test to determine whether a particular worker is an employee or an independent contractor. See Cent. Mgmt. Co. v. Indus. Comm’n, 162 Ariz. 187, 189–90 (App. 1989). We look “to the totality of the facts and circumstances of each case, examining various indicia of control.” Home Ins. Co. v. Indus. Comm’n, 123 Ariz. 348, 350 (1979). These indicia include:

[T]he duration of the employment; the method of payment; who furnishes necessary equipment; the right to hire and fire; who bears responsibility for workmen’s compensation insurance; the extent to which the employer may exercise control over the details of the work, and whether the work was performed in the usual and regular course of the employer’s business.

Id. “No one factor is determinative[.]” Munoz v. Indus. Comm’n, 234 Ariz. 145, 150 ¶ 16 (App. 2014).

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Related

Swichtenberg v. Brimer
828 P.2d 1218 (Court of Appeals of Arizona, 1991)
Holding v. Industrial Com'n of Arizona
679 P.2d 571 (Court of Appeals of Arizona, 1984)
Home Insurance v. Industrial Commission
599 P.2d 801 (Arizona Supreme Court, 1979)
Central Management Co. v. Industrial Commission
781 P.2d 1374 (Court of Appeals of Arizona, 1989)
Lovitch v. Industrial Commission
41 P.3d 640 (Court of Appeals of Arizona, 2002)
Henderson-Jones v. Industrial Commission
310 P.3d 976 (Court of Appeals of Arizona, 2013)
Danial v. Indus. Comm'n of Ariz.
434 P.3d 592 (Court of Appeals of Arizona, 2019)

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Bluebook (online)
J-King v. Conley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-king-v-conley-arizctapp-2025.