Wellpath, LLC v. Joseph Cox

CourtCourt of Appeals of Georgia
DecidedJanuary 10, 2024
DocketA23A1298
StatusPublished

This text of Wellpath, LLC v. Joseph Cox (Wellpath, LLC v. Joseph Cox) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wellpath, LLC v. Joseph Cox, (Ga. Ct. App. 2024).

Opinion

FIFTH DIVISION MCFADDEN, P. J., BROWN and MARKLE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

January 10, 2024

In the Court of Appeals of Georgia A23A1298. WELLPATH, LLC v. COX.

BROWN, Judge.

Joseph Cox sued Heather Lawrenz and WellPath, LLC, for injuries he sustained

when Lawrenz allegedly collided with a vehicle driven by Cox. Cox alleged that

Lawrenz was acting within the scope of her employment at the time of the collision

and that WellPath was therefore liable under the theory of respondeat superior. The

trial court denied WellPath’s motion to withdraw its admissions and granted Cox’s

motion for partial summary judgment on the issue of respondeat superior. WellPath

appeals these rulings, contending that (1) there is a genuine issue of material fact as

to whether Lawrenz was an employee or independent contractor and (2) the trial court erred in denying WellPath’s motion to withdraw its admissions.1 For the reasons

explained below, we (1) reverse the denial of the motion to withdraw and remand for

the trial court to reconsider its ruling, and (2) reverse the grant of partial summary

judgment to Cox.

Summary judgment is proper when there is no genuine issue of material fact and the movant is entitled to judgment as a matter of law. We apply a de novo standard of review to an appeal from a grant or denial of summary judgment, and we view the evidence, and all reasonable conclusions and inferences drawn from it, in the light most favorable to the nonmovant.

(Citations and punctuation omitted.) Augusta Chronicle v. Woodall, 360 Ga. App. 576

(859 SE2d 617) (2021). Viewed in the light most favorable to WellPath, the

nonmoving party, the evidence shows that Lawrenz, a resident of South Carolina, was

under contract as an “ambassador” for WellPath, which had a contract to provide

medical care to prisons in the State of Georgia. Lawrenz was tasked with assisting

prison health service administrators with the transition over to WellPath. According

to Lawrenz, those prisons included Dooly, Pulaski, Wilcox, Rutledge, and Bainbridge

1 We are not persuaded by Cox’s contention that WellPath abandoned this enumeration. 2 Correctional, and she was “a contractor that came in to assist [the prisons] with the

transition” and also help the prisons prepare for upcoming audits by the American

Correctional Association.2

On December 14, 2021, Lawrenz stayed in a hotel in Bainbridge. At

approximately 6:10 a.m. on December 15, 2021, Lawrenz was driving in her own

vehicle from her hotel to either Pulaski or Dooly prison, when she collided with Cox’s

vehicle. At the time of the collision, Lawrenz was on the phone with her husband;

Lawrenz’s car was equipped with Bluetooth and her phone would have been

connected to the Bluetooth. Cox sustained serious injuries and subsequently filed a

complaint against Lawrenz on February 3, 2022.

Procedural Facts

In her response to Cox’s requests for admission, filed on April 29, 2022,

Lawrenz admitted that on the date of the accident, she was a “contractor of

WellPath.” Lawrenz was deposed on August 26, 2022. The only persons present for

the deposition were Cox’s attorney, Lawrenz’s attorney, and the attorney for the

2 During her deposition, Cox’s counsel presented Lawrenz with her “Independent Contractor Agreement,” dated August 29, 2021, and asked her specific questions about the wording of the document and who at WellPath presented it to her or whether she had an attorney draw it up. 3 uninsured motorist carrier. On September 1, 2022, Cox moved to add WellPath as a

defendant. The trial court granted the motion, and on September 9, 2022, Cox filed

an amended complaint adding WellPath as a defendant and asserting that it was

vicariously liable for Lawrenz’s alleged negligence based on the doctrine of respondeat

superior. WellPath was served with the amended complaint and various discovery

requests (interrogatories, requests for production of documents, and requests for

admission) on September 20, 2022, but the proof of service was not filed until October

11, 2022.3 On November 8, 2022, Cox filed a motion for partial summary judgment

on the vicarious liability claim, asserting erroneously that because WellPath had failed

to respond timely to Cox’s requests for admission, it admitted that at the time of the

collision, Lawrenz “was an employee and/or agent of Defendant WellPath” and that

because WellPath retained the right to control the time, manner, and method of

Lawrenz’s work, she was not an independent contractor. On the same day, the trial

court ordered a “hearing on all issues” for December 15, 2022, and mandated that

3 Pursuant to OCGA § 9-11-4 (h), “[t]he person serving the process shall make proof of such service with the court in the county in which the action is pending within five business days of the service date. If the proof of service is not filed within five business days, the time for the party served to answer the process shall not begin to run until such proof of service is filed.” Accordingly, WellPath’s answer and discovery responses were not due until November 11, 2022. 4 WellPath file an answer or responsive pleading within 20 days.4 WellPath filed an

answer and responses to the requests for admission (“RFA”) on November 10, 2022.

RFA #6 stated, “Please admit that at the time of the December 15, 2021 collision

Defendant Lawrenz was an employee and/or agent of Defendant WellPath.” In

response, WellPath stated, “Admitted.” In its answer, WellPath also admitted that

Lawrenz was an employee on the date of collision, but denied that she was acting

within the course and scope of her employment at the time of the incident.

The trial court held a hearing on the motion for partial summary judgment on

December 15, 2022. Lawrenz’s deposition was filed with the trial court on December

30, 2022. On January 5, 2023, the trial court set a second hearing on the motion for

partial summary judgment, to be held on January 16, 2023. On January 13, 2023,

WellPath filed a motion to withdraw RFA #6, contending that it was unaware that

Lawrenz was an independent contractor until it received a copy of her deposition and

deposition exhibits on December 21, 2022, and January 4, 2023, respectively. In

support of the motion, WellPath filed the affidavit of Lawrenz’s direct supervisor at

4 In a subsequent e-mail to the parties, the trial court noted that the tolling provisions of OCGA § 9-11-4 (h) applied to WellPath’s answer and discovery responses. 5 WellPath, who averred that WellPath hires independent contractors such as Lawrenz

to assist it with the transition of multiple prison medical facilities to WellPath’s

control and that at the time of the collision, Lawrenz was providing services under an

independent contractor agreement, and that WellPath did not control the time,

manner, or method of Lawrenz’s contractual duties. A copy of the independent

contractor agreement was attached to the affidavit. On January 16, 2023, the trial court

held a second hearing, during which counsel for WellPath explained that it had not

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