(concurring in result). I concur in the majority’s decision to reverse, but write separately because I disagree with the majority’s reasoning. I do not agree with the majority that the volunteer doctrine is limited to respondeat superior liability. I would, however, hold that the trial court erred in granting summary disposition because a question of fact exists whether the volunteer doctrine applies in this case.
*527The majority holds that the volunteer doctrine does not apply in this case because the doctrine, as described in Diefenbach v Great Atlantic & Pacific Tea Co, 280 Mich 507; 273 NW 783 (1937), is a limitation purely on respondeat superior liability. I do not agree that the volunteer doctrine is so limited.
Our Supreme Court stated in Pace v Gibson, 357 Mich 315, 319-320; 98 NW2d 654 (1959), that it recognized in Diefenbach “the general rule that one who is merely a volunteer in rendering services to another cannot recover if injured because of negligence, there being no duty other than not to injure him by willful or wanton act.” The Court’s description of the doctrine is consistent with that of other general authorities. 65 CJS, Negligence, § 63(148), p 935, states:
A person engaged in work, or the owner or occupier of land, owes no duty to exercise ordinary care toward a mere volunteer, and is liable only for gross negligence, willfulness, or wantonness.
27 Am Jur 2d, Employment Relationship, § 282, p 772, similarly describes the volunteer doctrine as follows:
The duties required by law of an employer with respect to its employees are generally not owed by the employer to a person whom the employer has not authorized to render services as an employee. In particular, a person who of his own volition volunteers to do work for another without that person’s knowledge generally cannot recover for breach of a duty owed by an employer to an employee.
The foregoing authorities demonstrate that the volunteer doctrine sets forth the duty of care that a master owes a volunteer. “Duty is essentially a question of whether the relationship between the actor and the injured person gives rise to any legal obliga*528tion on the actor’s part for the benefit of the injured person.” Moning v Alfono, 400 Mich 425, 438-439; 254 NW2d 759 (1977) (emphasis added). The duty arising out of the master and volunteer relationship is not limited to a specific form of liability. Therefore, the doctrine applies whether the master’s liability arises from his own act or that of a servant.
The majority additionally contends that the Restatement Torts, 2d, and Michigan case law regarding assumption of risk support its assertion that the volunteer doctrine is limited to vicarious liability in the master and servant context. Contrary to the majority’s assertion, however, 2 Restatement Torts, 2d, § 496A, pp 560-565, does not discuss volunteers per se, it merely discusses situations where someone “voluntarily” assumes a risk. In Felgner v Anderson, 375 Mich 23, 39, 45, 56; 133 NW2d 136 (1965), also cited by the majority, the Court noted that in prior cases it had applied the doctrine of assumption of risk in the context of master and servant relationships to limit the employer’s liability for the consequences of another’s (a servant’s) act. The Court cited language in Pace, supra, as an example of a case where uncertainty exists in how the Court used language of assumed risk. Felgner, supra at 51. In Pace, supra at 325, the Court stated:
Under the circumstances here presented it cannot be said as a matter of law that plaintiff was a mere volunteer. He did not, in consequence, assume the risk of being injured by ordinary negligence on the part of defendant or his employee, and may not be charged with contributory negligence on such basis.
Our Supreme Court’s use of assumption of risk language in Pace, however, is contrary to the rationale *529for the volunteer doctrine as set forth in Diefenbach, supra.
In Diefenbach, supra, the Court neither discussed assumption of risk as the underlying rationale for the volunteer doctrine nor limited the doctrine to respondeat superior liability. The Court rejected alternate rationales for the volunteer doctrine, explaining that the “better view would appear to be that the volunteer cannot recover because no duty is owed to him other than not to injure him by wilful or wanton acts.” Id. at 512. The Court then quoted expensively from Atlanta & W P R Co v West, 121 Ga 641; 49 SE 711 (1905). The West court reasoned that a volunteer is not entitled to the same degree of diligence on the part of the master as the master is bound to exercise with reference to servants because a volunteer is not a servant. The West court noted that in prior cases involving injuries inflicted by fellow servants, courts equated a volunteer with a servant because a volunteer could stand in no better position than a servant, who could not recover from the master for injuries caused by a fellow servant. The West court, however, further explained that when the Legislature has abrogated the rule of nonliability, volunteers must be assigned their true positions and the obligations of master and servant do not arise between them. Diefenbach, supra at 512-513 (quoting West, supra). Given the focus on the relationship between the master and the volunteer, not the identity of the negligent actor, the Diefenbach Court’s rationale simply does not support limiting the volunteer doctrine to respondeat superior liability.
Further, contrary to the majority’s assertion, the volunteer doctrine, as adopted by the Court in Die*530fenbach, does not “insulate from tort liability any person directly liable for negligence toward a volunteer.” Ante at 523. The volunteer doctrine does not apply to an injured volunteer’s claim against a master’s allegedly negligent servant because the doctrine establishes the duty owed by a master to a volunteer, not the duty owed by the master’s servant to a volunteer. Georgia Hwy Express, Inc v Rountree, 130 Ga App 792, 794; 204 SE2d 512 (1974). Regarding the master’s negligence, however, the doctrine clearly provides that the master owes the volunteer only a duty of care not to injure him by wilful or wanton acts. Diefenbach, supra at 512-513.
In the end, the majority acts contrary to both our Supreme Court’s written word and underlying rationale in limiting the Court’s holding in Diefenbach, supra, to respondeat superior liability. This Court has no authority to take such action because a decision of our Supreme Court is binding on this Court until the Supreme Court overturns it. O’Dess v Grand Trunk W R Co, 218 Mich App 694, 700; 555 NW2d 261 (1996). Whether the volunteer doctrine should be limited in Michigan to respondeat superior liability, otherwise modified, or abandoned altogether, are questions properly addressed to our Supreme Court. Absent later decisions by the Court that call into doubt the breadth of Diefenbach’s holding, this Court may not limit that holding, but rather, must apply it as written until further consideration of the issue by our Supreme Court.
I nonetheless concur in the majority’s decision to reverse because a question of fact exists whether the volunteer doctrine applies in this case. In order for the volunteer doctrine to apply, the master must not *531have authorized the volunteer to render services. Stated otherwise, the master must not have invited the volunteer to render services. 65 CJS, Negligence, § 63(148), pp 935-936 (“One who is engaged in work or an operation owes to another who undertakes to assist him as a mere volunteer, without invitation and without contractual relationship, no duty of care .... [A] duty to exercise care may exist. . . because such person is invited or requested to act”) (emphasis added); 27 Am Jur 2d, Employment Relationship, § 282, p 772 (“[A] person who of his own volition volunteers to do work for another without that person’s knowledge generally cannot recover for breach of a duty owed by an employer to an employee.”) (emphasis added). The passage from West, supra, at 644 quoted by the Court in Diefenbach, supra at 512, likewise makes this distinction:
One who, without any employment whatever or at the request of a servant who has no authority to employ other servants, voluntarily undertakes to perform service for the master, is a mere volunteer and not entitled to that degree of diligence on the part of the master which the latter is bound to exercise with reference to his servants. [Emphasis added.]
Other courts have reached the same result where the master invites the injured person to act by labeling the injured person a “gratuitous servant” or “gratuitous employee,” rather than a volunteer.1 See Milbank *532Mut Ins Co v Dairyland, Ins Co, 373 NW2d 888, 893 (ND, 1985); Murdock v Peterson, 74 Nev 363, 365; 332 P2d 649 (1958).
In both Diefenbach and Pace, the master’s servant allegedly solicited the help of the injured person or invited the injured person to act. The master did not acquiesce in the arrangement or grant the servant the authority to engage the services of the injured person. Compare Kavigian v Lonero, 312 Mass 603; 45 NE2d 823 (1942). Accordingly, both cases turned on whether the injured person was, in fact, a volunteer. In Pace, the Court held that the injured person was not a volunteer because he had an interest in the work. See also Fletcher v Kemp, 327 SW2d 178, 182 (Mo, 1959); Rountree, supra at 794. By contrast, the master (Urbane) in the instant case allegedly invited the volunteer (Hawkins) to act. If Urbane did invite Hawkins to act, the volunteer doctrine would not apply, irrespective of whether Hawkins would otherwise be classified as a volunteer. 2
*533The mvitation-to-act element also explains why this Court did not consider the volunteer doctrine in the cases cited by the majority — Leveque v Leveque, 41 Mich App 127, 131; 199 NW2d 675 (1972), and Doran v Combs, 135 Mich App 492, 494-496; 354 NW2d 804 (1984). 3 In those cases, the master authorized or invited the injured person to perform services. As Leveque and Doran demonstrate, the volunteer doctrine generally does not apply in social settings, such as the rendering of neighborly assistance, because those cases typically involve a master who authorizes or invites the volunteer to act.
In the instant case, a question of fact existed whether Urbane requested or invited Hawkins to assist him in moving his personal possessions. If the volunteer doctrine does not apply, Urbane owed Hawkins a duty of ordinary care while backing up the truck. McCullough v Ward Trucking Co, 368 Mich 108; 117 NW2d 167 (1962); Hopkins v Lake, 348 Mich 382, 389, 398; 83 NW2d 262 (1957); Jenkins v Bentley, 277 Mich 81, 84; 268 NW 819 (1936). Accordingly, the trial court erred in granting summary disposition for Urbane, because a question of fact existed whether the volunteer doctrine applies in this case.
Severinson v Nerby, 105 NW2d 252, 256 (ND, 1960), is an example of circumstances where the court may apply the volunteer doctrine even when the volunteer renders services in the master’s presence because the master did not invite the volunteer to act. In Severinson, the defendant was an independent contractor who contracted with the plaintiffs employer to construct a concrete foundation for a building. The plaintiff was at the job site on behalf of his employer to furnish water for defend*532ant’s cement mixer under the contract. The defendant asked the plaintiff if he had a grease gun, because the defendant needed to grease his cement mixer. The plaintiff retrieved a grease gun and, without prompting from the defendant, greased the mixer and injured himself in performing the task. The court held that the plaintiff was a volunteer and not a gratuitous employee because the defendant did not expressly or implicitly request his help.
The invitation-to-act element is not the equivalent of invitee status. I agree with the trial court that Hawkins would be classified as a volunteer if the volunteer doctrine applies in this case. A person’s status as a volunteer turns on whether he has an interest in the work. Chamberlain v Haanpaa, 1 Mich App 303, 309; 136 NW2d 32 (1965). A person in regular pursuit of his own business is not a volunteer for purpose of the volunteer doctrine. See id. at 309-310. I reject Ryder’s argument that an informal social exchange of assistance satisfies the interest test. This gratuitous rendering of services in return for a past favor does not establish an interest in the work sufficient to create an issue of fact whether a person is a volunteer. The volunteer doctrine, however, is founded on the notion that no duty of ordinary care arises between a master and a volunteer because *533the master never agreed to enter into something akin to an employment relationship with the volunteer, i.e., the master did not invite the volunteer to act. When the master invites the volunteer to act, whether gratuitously or not, application of the volunteer doctrine would not further this underlying rationale.
In another case cited by the majority, White v Badalamenti, 200 Mich App 434; 505 NW2d 8 (1993), the master sued the volunteer for injuries sustained when she slipped and fell while walking on the volunteer’s sidewalk. Thus, the volunteer doctrine did not even arguably apply because the case did not involve the duty owed by a master to a volunteer.