Welch v. Home Two, Inc.

783 A.2d 419, 172 Vt. 632
CourtSupreme Court of Vermont
DecidedSeptember 19, 2000
Docket00-236
StatusPublished
Cited by12 cases

This text of 783 A.2d 419 (Welch v. Home Two, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Welch v. Home Two, Inc., 783 A.2d 419, 172 Vt. 632 (Vt. 2000).

Opinions

Norman and Bobbie Jo Welch appeal from an order of the Chittenden Superior Court dismissing their negligence claim against defendant, Home Two, Inc. Plaintiffs contend that the court erred in finding that Home Two, Inc. was Norman Welch’s statutory employer within the meaning of the Workers’ Compensation Act, 21 V.S.A. §§ 622, 624 (the Act), and that plaintiffs’ common law claims are therefore barred under the employer-immunity of the Act. We affirm.

In January 1998, Norman Welch worked as a project supervisor for Leelair Brothers Inc., an electrical subcontractor, at a construction project at the Charlotte Library. Home Two, Inc. was the general contractor of the Charlotte Library construction project. On January 21, while working at the construction site, Welch injured his shoulder, attempting to ascend a staircase which he claims was negligently selected and installed by Home Two. Due to the accident, Welch was disabled from work for one year, underwent surgery on his shoulder and sustained a permanent partial impairment. As a result of his injury, Welch received workers’ compensation benefits through Leelair Brothers’ coverage.

No written employment contracts were executed between Home Two and either Leelair Brothers or Welch. However, Home Two regularly contracted with independent electrical subcontractors, such as Leelair Brothers, to perform work on its construction projects.

After his injury, Welch1 brought a negligence action against Home Two, claiming that it negligently installed a staircase at the construction site, and knowingly created “an unreasonable risk of danger.” Home Two filed a motion to dismiss pursuant to V.R.C.P. 12(b)(6), arguing that as Welch’s statutory employer under the Act, 21 V.S.A. §§ 622, 624, it was entitled to immunity from suit by an injured employee of an independent subcontractor. Welch opposed the motion, filing a statement of material facts and an affidavit.2 The superior court granted [633]*633Home Two’s motion to dismiss in a one sentence opinion which states, “General contractor having control of premises is statutory employer.”

. On appeal, Welch claims the court erred in concluding that Home Two was Welch’s employer. We disagree. The rights and remedies of Vermont’s Workers’ Compensation Act granted to an employee on account of a personal injury for which the employee is entitled to compensation under the provisions of the Act are intended to be exclusive, “[ejxcept as provided in subsection 618(b) and section 624 of [Title 21].” 21 V.S.A. § 622. Here, Welch, having elected to claim workers’ compensation (see § 618(b)), asserts that his acceptance of compensation benefits should not be deemed to be an election of remedies because Home Two is not Welch’s employer within the meaning of 21 V.S.A. § 624(a).3 Welch asserts that Home Two cannot be considered an employer within the ambit of § 624(a) because (1) Home Two did not control the worksite premises, and (2) because Welch received workers’ compensation benefits from subcontractor, Leclair Brothers, and not Home Two, the general contractor.

In essence, Welch attempts to preserve the option of collecting workers’ compensation benefits from the subcontractor and suing the general contractor for negligence by application of a statutory employer “test” that would insulate a general contractor from the definition of “employer.” We have long held that in determining whether an employer-employee relationship is covered by the Workers’ Compensation Act, the language of the law “is all-embracing.” Morrisseau v. Legac, 123 Vt. 70, 76, 181 A.2d 53, 57 (1962). The Workers’ Compensation Act defines “employer” to include:

the owner or lessee of premises or other person who is virtually the proprietor or operator of the business there carried on, but who, by reason of there being an independent contractor or for any other reason, is not the direct employer of the workers there employed.

21 V.S.A. § 601(3). As we have previously stated, “[t]his language specifically and unambiguously covers multiple-employer business situations.” Candido v. Polymers, Inc., 166 Vt. 15, 17, 687 A.2d 476, 478 (1996).

Welch notes that in Candido we held that in the absence of a written employment contract, “[t]he most important [634]*634consideration in finding implied consent [by the employee to the employment relationship] is whether the employee submitted to the employer’s direction and control.” Id. at 21, 687 A.2d at 480. The employment relationship in Candido differs markedly, however, from the one at issue in the present case. In Candido, the defendant, Polymers, Inc., had a contract with an employment agency which provided temporary workers. The plaintiff, one such temporary employee, was injured on the job while working at the defendant’s plant, and received workers’ compensation benefits from the employment agency.

As in the instant case, the plaintiff in Candido argued that the defendant was not plaintiffs employer within the meaning of the Workers’ Compensation Act and thus was subject to common law liability. Id. at 20, 687 A.2d at 480. In determining whether the plaintiff consented to the employment relationship with the defendant, we found that the plaintiff clearly accepted the defendant’s direction and control. But the inquiry that was necessary in Candido, i.e., to ensure that in a “lent-employee” situation the employee’s common law rights were not being affected by the private arrangement between two employers without the employee’s consent, is different from the relevant inquiry where a statutory employment relationship exists. See 6 A. Larson & L. Larson, Larson’s Workers’ Compensation Law § 111.04[l][c], at 111-30 (2001) (where “state has, for various policy reasons, decreed by statute that certain legal liabilities and relations shall follow if parties fit into a particular employment pattern,” different branches of law, that of statutory employees and that of lent employees, should not be confused).

Within the general contractor construction context, the facts of the instant case fall within an employment pattern well known to, and recognized by, the Legislature. General contractors typically “outsource” specific responsibilities within the overall construction project to subcontractors. To require general contractors to demonstrate direct control and supervision of workers hired directly by subcontractors would contravene the nearly universal approach of Workers’ Compensation Acts intended to make the general contractor the employer for purposes of extending coverage. See id. at § 111.04[l][a], at 111-21 (“Since the general contractor is ... in effect, made the employer for the purposes of the compensation statute, it is obvious that it should enjoy the regular immunity of an employer from third-party suit when the facts are such that it could be made liable for compensation; and the great majority of cases have so held.”).

Similarly, Welch’s assertion that the general contractor cannot be said, as a matter of law, to be “virtually the proprietor or operator of the business there carried on [the premises]” would effectively remove general contractors from the statutory definition of employer unless they were the owners or lessees of the premises. See 21 V.S.A. § 601(3).

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Welch v. Home Two, Inc.
783 A.2d 419 (Supreme Court of Vermont, 2000)

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Bluebook (online)
783 A.2d 419, 172 Vt. 632, Counsel Stack Legal Research, https://law.counselstack.com/opinion/welch-v-home-two-inc-vt-2000.