dissenting.
[¶ 20] In our previous cases addressing whether a person is an independent contractor or an employee, we have utilized an analysis based on criteria applying the general dictates of SDCL 61-1-11(2) to the particular facts of the case. Midland Atlas Co., Inc., v. Dep’t of Labor, 538 N.W.2d 232 (S.D.1995) (sales representatives for atlas publisher); Egemo v. Flores, 470 N.W.2d 817 (S.D.1991) (log cutter); In Re Appeal of Hendrickson’s Health Care, 462 N.W.2d 655 (S.D.1990) (nurses and nurses’ aides); Dep’t of Labor v. Tri State Insulation Co., 315 N.W.2d 315 (S.D.1982) (sales person for insulation company). Here, such analysis is unnecessary as a specific statute exists to provide us the answer whether these carriers are “customarily engaged in an independently established *589trade, occupation, profession or business.” Id. SDCL 61-1-26 provides:
As used in this title, unless the context otherwise plainly requires, the term ‘employment’ shall not include service performed by an individual under the age of eighteen in the delivery or distribution of newspapers or shopping news, not including delivery or distribution to any point for subsequent delivery or distribution.
[¶ 21] This provision demonstrates that the Legislature has specifically expressed itself on the issue of unemployment insurance tax liability for employees who distribute shopping news and determined that there should be no such liability for those delivery persons under age eighteen. “The legal maxim ‘ex-pressio unius est exelusio alterius’ means ‘the expression of one thing is the exclusion of another.’ The maxim is a general rule of statutory construction.” Aman v. Edmunds Cent. School Dist. 22-5, 494 N.W.2d 198, 200 (S.D.1992). Application of that maxim in this instance means that the Legislature also intended there should be unemployment insurance tax liability for any shopping news delivery person age eighteen or over.
[¶ 22] Here, there is no dispute between the parties over the fact that, under SDCL 61-1-26, Shoppers Guide bears no unemployment insurance tax liability for any of its carriers under age eighteen. However, the record reflects that seventeen of its carriers, including Lindermann, are eighteen or older. Accordingly, the strict construction of SDCL 61-1-26 mandated by its status as a tax exemption statute clearly requires unemployment insurance tax liability for those seventeen adult carriers and any other carriers similarly situated. In re State & City Sales Tax Liability, 437 N.W.2d 209, 211 (S.D.1989).
[¶ 23] SDCL 61-1-26 aside, Shoppers Guide fails in its burden of proof to establish its carriers are independent contractors. It is appropriate to carefully limit exemptions from the employment insurance law as its purpose is not to tax employers to fill the state treasury, but to “avoid the risk or hazards that will befall those who, because of employment, are dependent upon others for their livelihood.” Princess House, Inc. v. Dep’t of Industry, 111 Wis.2d 46, 330 N.W.2d 169, 180 (1983). Consistent with that policy, independent contractors are exempt because unemployment insurance “is designed to exclude from coverage those persons who are unlikely to be dependent upon others, even though they may perform services for others, because they have their own separately established business.” Id. See also Hendrickson’s, 462 N.W.2d at 659.
[¶24] Our eases focus on a proprietary interest test. It is defined in Tri State, 315 N.W.2d at 316, as follows:
The language used [in SDCL 61-1-11] contemplates that one engaged in an independently established trade, occupation, profession or business has a proprietary interest therein to the extent that he can operate it without hindrance from any individual whatsoever. An established business is one that is permanent, fixed, stable and lasting.
Id.
[¶ 25] In this case, just as with the nurses in Hendrickson’s, there is no evidence that the carriers hold themselves out to the public as engaged in an independent business which exists separate and apart from Shopper’s Guide. There is no evidence that they advertise their delivery services; there is no evidence that the carriers have any clientele independent of that provided by Shopper’s Guide; and there is no evidence that they have business premises or business cards. Unlike the salespersons in Tri State and Midland, here there is no evidence of any particular skill in which the carriers hold a proprietary interest.1 In fact, delivery of *590newspapers is a job which society and the law recognize can be safely and competently performed by children. See SDCL 61-1-26. Unlike the log cutter in Egemo, there is no evidence of any sort of substantial financial investment made by the carriers in their own business.
[¶ 26] Based upon the foregoing analysis,2 there is no evidence that the Shopper’s Guide carriers are assuming the risk of their own unemployment with a proprietary interest in an enterprise created and existing separate and apart from their relationship with Shopper’s Guide. Hendrickson’s, supra. There is no evidence that the carriers have a proprietary interest in an enterprise that will survive the termination of their relationship with Shopper’s Guide. Id. Salespersons and log cutters are professionals at their craft who likely devote their working years to their calling. Can the same be said of paper carriers? If the new standard is now that the person in question “have a proprietary interest in their ability to provide prompt and efficient delivery services,” then it will be the unusual person who is not exempted as most persons performing tasks for compensation should have as their goal to provide their services in a prompt and efficient manner.
[¶ 27] For the foregoing reasons I respectfully dissent and would affirm the circuit court.
[¶ 28] SABERS, J., joins this dissent.
. The act of selling something to a customer when that customer would not ordinarily seek to otherwise purchase that item is a skill not possessed by the public at large. In Tri State, the salesmen sold insulation and siding for homes. In Midland, the salesmen sold atlases. These products are not necessities of life, such as food and shelter, that a potential customer would ordinarily seek out without some outside inducement to purchase them. In both cases this skill at sales was directly related to compensation. No sales — no compensation. In contrast, the carriers in the case now before us do not have to *590sell anything to get paid. They give their publication away for free.
. The majority at page 587 sets forth thirteen criteria which it argues support the conclusion that adult carriers are independent contractors exempt from this tax. Yet, the same criteria apply to carriers who are children and the Legislature felt it necessary to pass SDCL 61-1-26 to exempt these children from the payroll tax.