Grothe v. Olafson

COMPTON, Justice,

concurring in part, dissenting in part.

Although I otherwise agree with the court’s resolution of this appeal, I disagree with the conclusion that the superior court did not err in finding that Olafson was an employee of Grothe’s, and I therefore also disagree with the conclusion that Olafson’s recovery should not be reduced by the amount of his comparative negligence.

As the court indicates, the appropriate test by which to determine whether Olafson was an employee or an independent contractor is that which we set forth in Ostrem v. Alaska Workmen’s Compensation Board, 511 P.2d 1061, 1063 (Alaska 1973):

With reference to the character of claimant’s work or business the factors are: (a) the degree of skill involved; (b) the degree to which it is a separate calling or business; and (c) the extent to which it can be expected to carry its own accident burden. The relationship of the claimant’s work or business to the purported employer’s business requires consideration of: -(a) the extent to which claimant’s work is a regular part of the employer’s regular work; (b) whether claimant’s work is continuous or intermittent; and (c) whether the duration is sufficient to amount to the hiring of continuing services as distinguished from contracting for the completion of the particular job.

Focusing first on the character of Olaf-son’s work, it is apparent that Olafson’s work both involved special skills and was a “separate calling” from Grothe’s business. Thus, the first two factors indicate that Olafson was an independent contractor rather than an employee. The third factor to be considered when focusing on the character of Olafson’s work is the extent to which Olafson could be expected to carry his own insurance. The superior court concluded that the inherent danger of Olaf-son’s work with dynamite made it economically unreasonable to expect Olafson to obtain his own insurance. This factor, according to the court, weighs in favor of considering Olafson an employee. There is no indication, however, that any evidence was presented to the court establishing whether or not persons performing the same type of work as Olafson obtain their own insurance. Similarly, there is no indication of evidence establishing how much it would have cost Olafson to obtain his own insurance and what percentage of his compensation the cost of insurance would have been. It therefore appears that there was no eviden-tiary basis for the court’s finding that it was unreasonable to expect Olafson to obtain his own insurance. If one is to engage in idle speculation, it makes as much sense, if not more, to assume that Olafson was provided sufficient compensation for his inherently dangerous work to permit him to obtain his own insurance.

*612The next step in the analysis is to examine the relationship between Olafson’s work and Grothe’s business. It is undisputed that Olafson’s work was intermittent in nature. The short duration of his work for Grothe indicates that he was “contracting for the completion of the particular job.” Ostrem, 511 P.2d at 1063. Both of these facts strongly suggest that Olafson was an independent contractor rather than an employee. The final consideration is “the extent to which claimant’s work is a regular part of the [purported] employer’s regular work.” Id. The superior court concluded that drilling and blasting was a regular part of Grothe’s business because Grothe had previously been involved in extracting rock in the course of developing subdivisions. The court therefore found that Olaf-son’s work was a regular part of Grothe’s regular work. I believe this misinterprets the test. As we indicated in Ostrem, it is not whether the general type of work performed is a regular part of the employer’s or contractor’s work, but whether the individual in question regularly works for the employer or contractor. “Does he work for many people, ‘on call’, for a few businesses, or for a single employer?” Id. at 1064 n. 5. Olafson did not regularly work for Grothe or function as a regular part of Grothe’s business. Instead, he worked for Grothe on only two prior occasions. The rest of the time he worked for various other contractors.

I believe that all of the facts in this case indicate that Olafson was an independent contractor and not an employee of Grothe’s. The “significant factors” relied upon by this court in affirming the superior court on this “extremely close” question are the supposed unreasonableness of requiring Olafson to provide his own insurance and “the general trend towards liberalizing the scope of workers’ compensation coverage.” 659 P.2d at 606 & n. 10. These are merely policy considerations, which I believe could be sufficient to tilt the scales in favor of finding employee status if some facts indicated employee status while other facts indicated independent contractor status. I do not believe, however, that they are sufficient to support a finding of employee status when all of the facts contradict this finding, as they do in this case. Accordingly, I believe the superior court erred in finding that Olafson was an employee of Grothe’s, rather than an independent contractor.

This does not effect Olafson’s claim against Grothe, except as to the issue of whether comparative negligence can be raised by Grothe as a defense to the action. We have repeatedly held that an owner or general contractor is liable for his own negligence that causes injury to his independent contractors and their employees. Sloan v. Atlantic Richfield Co., 552 P.2d 157, 160 (Alaska 1976). See also Everette v. Alyeska Pipeline Co., 614 P.2d 1341, 1347 (Alaska 1980); Hammond v. Bechtel Inc., 606 P.2d 1269, 1274 (Alaska 1980); Hobbs v. Mobil Oil Corp., 445 P.2d 933, 934 (Alaska 1968). I agree with the conclusion that the superior court did not err in finding that Grothe was negligent toward Olafson and that this negligence resulted in Olafson becoming disabled. Thus, I believe the court properly determined that Olafson was entitled to recover damages from Grothe.

The superior court initially determined that Olafson’s recovery should be reduced by twenty percent, which reflects the amount of Olafson’s comparative negligence as determined by the court. It subsequently ruled, however, that Grothe was not entitled to assert the defense of comparative negligence because Grothe had failed to carry insurance at the time of Olafson’s accident. On appeal, Grothe argues that the court erred in making this ruling. I agree on the basis of my conclusion that Olafson was not an employee. The statutory provision that an employer may not escape liability because of the employee’s negligence if the employer failed to carry insurance at the time of the injury is only applicable if the injured person was an employee. AS 23.30.055, AS 23.30.080. In view of my conclusion that Olafson was an independent contractor and not an employee, I would hold that it is irrelevant that Grothe was not carrying insurance at the *613time of the accident. I would accordingly order Olafson’s recovery to be reduced by the amount of his comparative negligence, but would otherwise affirm the judgment of the superior court.