Massey v. Werner Enterprises, Inc.

CourtCourt of Appeals of South Carolina
DecidedJanuary 7, 2010
Docket2010-UP-001
StatusUnpublished

This text of Massey v. Werner Enterprises, Inc. (Massey v. Werner Enterprises, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Massey v. Werner Enterprises, Inc., (S.C. Ct. App. 2010).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE.  IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

Marsha Elaine Massey, Employee, Respondent,

v.

Werner Enterprises, Inc., Employer, and Liberty Mutual Insurance Corp., Carrier, Appellants.


Appeal From Greenville County
 Doyet A. Early, III, Circuit Court Judge


Unpublished Opinion No. 2010-UP-001
Heard December 16, 2009 – Filed January 7, 2010
Withdrawn, Substituted, and Refiled March 24, 2010  


AFFIRMED IN PART, REVERSED IN PART


Stanley Case, of Spartanburg, for Appellants.

Donald Kamb, Jr., and Kathryn Williams, both of Greenville, for Respondent.

PER CURIAM: Marsha Massey filed this workers' compensation case[1] seeking to recover benefits for injuries she suffered while allegedly employed by Werner Enterprises, Inc.  Werner and its carrier, Liberty Mutual Group (collectively Appellants), denied the claim.  Appellants asserted the South Carolina Workers' Compensation Commission (the Commission) lacked jurisdiction and Massey was not entitled to benefits. 

After a hearing, the single commissioner awarded Massey temporary total disability benefits and causally related medical expenses, finding Massey was Werner's employee, not an independent contractor.  As an alternative ground, the single commissioner held Massey was a statutory employee under section 42-1-400 of the South Carolina Code.  The single commissioner awarded benefits based on an average weekly wage of $667.11.  Finally, the single commissioner held the Commission had jurisdiction because Massey was hired and employed in South Carolina. 

Appellants appealed to the Commission's appellate panel, which affirmed the single commissioner's findings.  Both the circuit court and this court affirmed.  Massey v. Werner Enterprises, Inc., Op. No. 2008-UP-126 (S.C. Ct. App. filed Feb. 20, 2008).  Appellants then filed a petition for a writ of certiorari with the supreme court.  The supreme court granted certiorari and remanded the action to this court for further consideration of the independent contractor issue in light of the supreme court's recent opinion in Wilkinson v. Palmetto State Transp. Co., 382 S.C. 295, 676 S.E.2d 700 (2009).[2]  Massey v. Werner Enterprises, Inc., Op. No. 2009-MO-034 (S.C. Sup. Ct. filed June 29, 2009).  The parties filed supplemental briefs with this court applying the Wilkinson opinion to the facts of this case.  We affirm in part and reverse in part.

LAW / ANALYSIS

I.  EMPLOYEE OR INDEPENDENT CONTRACTOR

Relying on Wilkinson, Appellants argue Massey is not entitled to South Carolina Workers' Compensation benefits because she was an independent contractor for workers' compensation purposes.  We agree.

Although the parties' contract must be considered in determining the nature of their relationship, the description of the relationship set forth in the contract is not dispositive.  Kilgore Group, Inc. v. S.C. Employment Sec. Comm'n, 313 S.C. 65, 68-69, 437 S.E.2d 48, 50 (1993).  Rather, the test to determine whether an employer-employee relationship exists is if the alleged employer has the right and authority to control and direct the claimant's work or undertaking as to the manner or means of its accomplishment.  S.C. Workers' Comp. Comm'n v. Ray Covington Realtors, Inc., 318 S.C. 546, 547, 45 S.E.2d 302, 303 (1995).  In determining the right of control, an appellate court must examine the following four factors: (1) direct evidence of the right or exercise of control; (2) furnishing of equipment; (3) method of payment; and (4) right to fire.  Tharpe v. G.E. Moore Co., 254 S.C. 196, 200, 174 S.E.2d 397, 399 (1970).  In Dawkins v. Jordan, the supreme court approved of adding the following framework to the analysis:

[F]or the most part, any single factor is not merely indicative of, but, in practice, virtually proof of, the employment relation; while, in the opposite direction, contrary evidence is as to any one factor at best only mildly persuasive evidence of contractorship, and sometimes is of almost no such force at all.

341 S.C. 434, 439, 534 S.E.2d 700, 703 (2000) (quoting Arthur Larson & Lex K. Larson, 3 Larson's Workers' Compensation Law § 61.04 (2000)).

In Wilkinson, however, the supreme court overruled the approach set forth in Dawkins, stating "[we] overrule Dawkins' analytical framework, for it most assuredly skews the analysis to a finding of employment.  We return to our jurisprudence that evaluates the four factors with equal force in both directions."  382 S.C. at 300, 676 S.E.2d at 702.

Here, after considering the parties' contract and evaluating the four factors with equal force, we hold Massey was an independent contractor. 

Massey admits she and her husband entered into a "contract" with Werner to lease their truck pursuant to an owner-operator agreement. Moreover, Massey concedes she signed an "Owner-Operator Compensation Coverage Agreement," wherein she is referred to as a "Contractor," and she sought workers' compensation coverage under Nebraska law.  Further, in a "Declaration of Employment Status" document, Massey declared she was "self-employed."  See Kilgore Group, 313 S.C. at 68-69, 437 S.E.2d at 50 (holding the description of the parties' relationship as set forth in the parties' contract must be considered, but the description is not dispositive in determining the nature of their relationship). 

An examination of the four factors also weighs in favor of holding Massey was an independent contractor.  As to the first factor, Massey retained the right to refuse any load Werner requested she haul.  Although Werner required Massey to affix Werner logos on the tractor, this requirement is in accordance with federal government regulations and should not be considered as evidence of control.  See Wilkinson, 382 S.C. at 302, 676 S.E.2d at 703.  Other evidence, however, shows Werner did maintain some control over Massey.  Massey could not drive the truck for personal errands or drive for another company.  In addition, Werner required Massey to use pre-approved fuel stops and service shops.  Werner also required Massey to install a global positioning satellite (GPS) system in her truck to track the location of the truck.  But see id. (holding the presence of a GPS system was not evidence of the motor carrier's control over its drivers when the system was for the benefit of customers tracking the shipment of goods).

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Related

South Carolina Workers' Compensation Commission v. Ray Covington Realtors, Inc.
459 S.E.2d 302 (Supreme Court of South Carolina, 1995)
Bryson v. Bryson
662 S.E.2d 611 (Court of Appeals of South Carolina, 2008)
Dawkins v. Jordan
534 S.E.2d 700 (Supreme Court of South Carolina, 2000)
Tharpe v. G. E. Moore Co.
174 S.E.2d 397 (Supreme Court of South Carolina, 1970)
Noisette v. Ismail
403 S.E.2d 122 (Supreme Court of South Carolina, 1991)
Kilgore Group, Inc. v. South Carolina Employment Security Commission
437 S.E.2d 48 (Supreme Court of South Carolina, 1993)
Olmstead v. Shakespeare
581 S.E.2d 483 (Supreme Court of South Carolina, 2003)
Wilkinson v. Palmetto State Transportation Co.
676 S.E.2d 700 (Supreme Court of South Carolina, 2009)
Smith v. T.H. Snipes & Sons, Inc.
411 S.E.2d 439 (Supreme Court of South Carolina, 1991)
Glasscock, Inc. v. United States Fidelity & Guaranty Co.
557 S.E.2d 689 (Court of Appeals of South Carolina, 2001)
ML-Lee Acquisition Fund, L.P. v. Deloitte
489 S.E.2d 470 (Supreme Court of South Carolina, 1997)
Nicholas v. Commonwealth
45 S.E.2d 302 (Supreme Court of Virginia, 1947)

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Massey v. Werner Enterprises, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/massey-v-werner-enterprises-inc-scctapp-2010.