Ronald Davis v. Tube-Tech Services, Inc. & American Liberty Insurance Company

CourtLouisiana Court of Appeal
DecidedApril 2, 2025
DocketWCA-0024-0573
StatusUnknown

This text of Ronald Davis v. Tube-Tech Services, Inc. & American Liberty Insurance Company (Ronald Davis v. Tube-Tech Services, Inc. & American Liberty Insurance Company) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ronald Davis v. Tube-Tech Services, Inc. & American Liberty Insurance Company, (La. Ct. App. 2025).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

24-573

RONALD DAVIS

VERSUS

TUBE-TECH SERVICES, INC. AND AMERICAN LIBERTY INSURANCE COMPANY

**********

APPEAL FROM THE OFFICE OF WORKERS’ COMPENSATION, DISTRICT 4 PARISH OF ACADIA, NUMBER 23-06351 PAULA MURPHY, WORKERS’ COMPENSATION JUDGE

SHARON DARVILLE WILSON JUDGE

Court composed of Sharon Darville Wilson, Gary J. Ortego, and Clayton Davis, Judges.

AFFIRMED.

Davis, J., dissents and assigns written reasons. Donovan J. O’Pry, II Bernard R. Minyard Grant J. Bratcher Miles C. Hesterly O’PRY LAW FIRM 2014 West Pinhook Road, Suite 507 Lafayette, Louisiana 70508 (337) 415-0007 COUNSEL FOR CLAIMANT/APPELLANT: Ronald Davis

David B. Parnell, Jr. BLUE WILLIAMS, LLC 1060 W. Causeway Approach Mandeville, Louisiana 70471 (504) 831-4091 COUNSEL FOR DEFENDANTS/APPELLEES: Tube-Tech Services, Inc. and American Liberty Insurance Company WILSON, Judge.

Claimant, Ronald Davis (Davis), appeals the ruling of the Workers’

Compensation Judge (WCJ) dismissing his claim for benefits against Tube-Tech

Services, Inc. (Tube-Tech). For the following reasons, we affirm.

I.

ISSUES

Davis alleges the following assignment of error: “The trial court erred in

granting Tube-Tech’s Exception of No Right of Action, as [] Davis was an employee

when he was injured in the course and scope of his employment.” The issue is

whether Davis was an independent contractor or an employee. If we find that Davis

was an independent contractor, we must then determine whether the manual labor

exception applies such that he would be eligible for benefits under the Louisiana

Workers’ Compensation Act.

II.

STANDARD OF REVIEW

It is well-settled that “[t]he distinction between employee and independent

contractor is a factual determination to be decided on a case-by-case basis.”

Fontenot v. J.K. Richard Trucking, 97-220, p. 7 (La.App. 3 Cir. 6/4/97), 696 So.2d

176, 180. Furthermore, “[w]hether an individual’s job involves manual labor is to

be considered from the particular facts and circumstances of each case[,]” and

whether an individual spends “a substantial part of his work time in manual labor”

is a finding of fact. Coleman v. Landstar Ranger, 03-1943, p. 2 (La.App. 1 Cir.

6/24/04), 886 So.2d 472, 473.

Factual determinations in workers’ compensation cases and rulings on

peremptory exceptions of no right of action where evidence is introduced at the

hearing are all subject to the manifest error standard of review. “[T]he issue to be resolved by the reviewing court is not whether the trier of fact was right or wrong,

but whether the factfinder’s conclusion was a reasonable one.” Stobart v. State

through Dep’t of Transp. & Dev., 617 So.2d 880, 882 (La.1993). Furthermore,

“[e]ven though an appellate court may feel its own evaluations and inferences are

more reasonable than the factfinder’s, reasonable evaluations of credibility and

reasonable inferences of fact should not be disturbed upon review where conflict

exists in the testimony.” Id.

III.

FACTS AND PROCEDURAL HISTORY

Davis was hired by Tube-Tech as a truck driver in October of 2022. Tube-

Tech is a company that inspects and cleans oilfield pipe for its customers. Tube-

Tech hires drivers to pick up and deliver the pipe. Tube-Tech owns one truck, which

is a cab and flatbed trailer, and uses a third-party company for additional trucks as

needed.

Blake Granger (Granger), the manager of Tube-Tech, testified that after about

two weeks of employment, Davis came to him to ask what Davis could “do to make

a little extra money.” Granger testified that he told Davis that “he could switch [from

W-2] to 1099, and there was a lot of tax benefits with it, . . . . So that was something

that we discussed with him, and he agreed upon that . . . . [s]o he could collect a

little extra money[.]” After the switch from W-2 to form 1099, Davis was paid $1.25

per mile and $15.00 per hour for any time he had to wait for the truck to be unloaded

by the customer. This amount was charged back to the customer by Tube-Tech.

On October 20, 2023, Davis was delivering a load in Texas and stopped to re-

secure it. When he exited the truck, he allegedly fell and injured his neck and back.

He filed a claim for workers’ compensation benefits, and Tube-Tech and its insurer,

American Liberty Insurance Company, filed an exception of no right of action, 2 alleging that Davis was not an employee of Tube-Tech and was performing services

as an independent contractor. The WCJ found that Davis was an independent

contractor and that the manual labor exception was not applicable. Accordingly, the

WCJ granted the exception of no right of action and dismissed Davis’ claims with

prejudice. This appeal followed.

IV.

LAW AND DISCUSSION

Independent Contractor Status

“Inherently, workers’ compensation is a remedy between an employer and an

employee; it follows then that absent an employer-employee relationship generally

there can be no compensation recovery.” Hillman v. Comm-Care, Inc., 01-1140, p.

6 (La. 1/15/02), 805 So.2d 1157, 1161. There is a statutory presumption of

employment status,1 which the employer can rebut by establishing that the person

was performing services as an independent contractor. Id. (footnote added).

Louisiana Revised Statutes 23:1021(7) defines an “[i]ndependent contractor”

as:

any person who renders service, other than manual labor, for a specified recompense for a specified result either as a unit or as a whole, under the control of his principal as to results of his work only, and not as to the means by which such result is accomplished, and are expressly excluded from the provisions of this Chapter unless a substantial part of the work time of an independent contractor is spent in manual labor by him in carrying out the terms of the contract, in which case the independent contractor is expressly covered by the provisions of this Chapter. The operation of a truck tractor or truck tractor trailer, including fueling, driving, connecting and disconnecting electrical lines and air hoses, hooking and unhooking trailers, and vehicle inspections are not manual labor within the meaning of this Chapter.

While “[t]he essence of the [employer-employee] relationship is the right to

control[,]” there are “four primary evidentiary factors considered in deciding”

1 “A person rendering service for another in any trades, businesses or occupations covered by this Chapter is presumed to be an employee under this Chapter.” La.R.S 23:1044. 3 whether such a relationship exists. Hillman, 805 So.2d at 1162 (alteration in

original), quoting Alexander v. J.E. Hixson & Sons Funeral Home, 44 So.2d 487,

488 (La.App. 1 Cir. 1950). The four factors are:

1. Selection and engagement;

2. Payment of wages;

3. Power of [d]ismissal;

4. Power of control.

Id. (alteration in original).

This court in Fontenot, 696 So.2d at 180, quoted Stovall v. Shell Oil Co., 577

So.2d 732, 738–39 (La.App. 1 Cir.), writ denied, 582 So.2d 1309 (La.1991), to

define the conditions that must be met in order to find that a principal and

independent contractor relationship exists:

1. There is a valid contract between the parties;

2.

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

Related

Stobart v. State Through DOTD
617 So. 2d 880 (Supreme Court of Louisiana, 1993)
Pitcher v. Hydro-Kem Services, Inc.
551 So. 2d 736 (Louisiana Court of Appeal, 1989)
Stovall v. Shell Oil Co.
577 So. 2d 732 (Louisiana Court of Appeal, 1991)
Kevin Associates, LLC v. Crawford
865 So. 2d 34 (Supreme Court of Louisiana, 2004)
Hillman v. Comm-Care, Inc.
805 So. 2d 1157 (Supreme Court of Louisiana, 2002)
State v. Payne
833 So. 2d 927 (Supreme Court of Louisiana, 2002)
Lewis v. Teacher's Pet, Inc.
621 So. 2d 867 (Louisiana Court of Appeal, 1993)
Kem Search, Inc. v. Sheffield
434 So. 2d 1067 (Supreme Court of Louisiana, 1983)
Teel v. Superior Scrap Metals
675 So. 2d 1169 (Louisiana Court of Appeal, 1996)
Fontenot v. JK Richard Trucking
696 So. 2d 176 (Louisiana Court of Appeal, 1997)
Harrington v. Hebert
789 So. 2d 649 (Louisiana Court of Appeal, 2001)
Riles v. Truitt Jones Const.
648 So. 2d 1296 (Supreme Court of Louisiana, 1995)
Alexander v. JE Hixson & Sons Funeral Home
44 So. 2d 487 (Louisiana Court of Appeal, 1950)
Sones v. Mutual of Omaha Insurance Company
272 So. 2d 739 (Louisiana Court of Appeal, 1973)
McGrew v. QUALITY CARRIERS, INC.
74 So. 3d 1253 (Louisiana Court of Appeal, 2011)
Duhon v. Briley
117 So. 3d 253 (Louisiana Court of Appeal, 2013)
Chaisson v. Louisiana Rock Monsters, LLC
140 So. 3d 55 (Louisiana Court of Appeal, 2014)
Coleman v. Ranger
886 So. 2d 472 (Louisiana Court of Appeal, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
Ronald Davis v. Tube-Tech Services, Inc. & American Liberty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-davis-v-tube-tech-services-inc-american-liberty-insurance-lactapp-2025.