(dissenting in part). Plaintiff Ford Berger1 filed this tort suit against 58 municipalities, police departments and individuals to recover for personal injury. Plaintiff was totally blinded and suffered severe facial disfigurement when he was struck in the face by rice kernels fired from a shotgun by a fellow police officer while they were participating in a training exercise of the tactical support unit of the South Oakland County Mutual Aid Pact.
Plaintiff was an employee of the Royal Oak Police Department at the time of the injury. During the training exercise he was acting as a sniper and was "captured” by other police officers. The injury occurred when he attempted to "escape” *377from a police vehicle and a shotgun loaded with rice was discharged at his face from a distance of less than five feet.
The lower court dismissed the complaint against all defendants on two bases: (1) that all defendants were either coemployees or the employer of plaintiff and, therefore, his exclusive remedy was under the Worker’s Disability Compensation Act, MCL 418.131; MSA 17.237(131), or (2) the defendants were entitled to governmental immunity under MCL 691.1407; MSA 3.996(107). Plaintiff appeals by right to challenge these findings.
I
The trial court granted blanket relief to all defendants. Perhaps this was the result of the large number of defendants as noted above. We are sympathetic with the judge’s response to the problem, having received several hundred pages of briefs and documents on appeal ourselves. However, in granting the blanket relief, the court granted judgment in favor of a number of defendants2 who had never appeared and against whom defaults had been entered. Plaintiff claims this was improper and we agree.
GCR 1963, 520.1 provides in part that, "[0]nce a default of any party has been duly filed or entered, that party shall not proceed with his case until his *378default has been set aside by the court in accordance with sub-rule 520.4.” If a party cannot proceed with his case until the default is set aside, it is improper for the court to grant judgment in his favor. As to those defendants who had been defaulted at the time the judgments were entered, the judgments are reversed and the case remanded to allow plaintiff to move for entry of a default judgment or other appropriate action. See note 2.
II
Several of the defendants who did answer below and eventually moved for summary or accelerated judgment under GCR 1963, 116.1(2) or 117.2(1) based those motions on the exclusive remedy provision of the Worker’s Disability Compensation Act, MCL 418.131; MSA 17.237(131).3 These defendants reasoned that under the mutual aid pact signed by the various cities, a type of joint venture had been entered into and, therefore, all the cities and police departments were coemployers and all the individuals were coemployees of plaintiff. The joint venture construction of the aid pact was adopted by the circuit court and has now been adopted by substantially all of the defendants participating in the appeal.
If plaintiff was injured by the act of a coem-ployee in a situation covered by the worker’s compensation act, this tort suit would be barred by the exclusive remedy provision of the act. Ayers v Genter, 367 Mich 675; 117 NW2d 38 (1962). The parties and the trial court seem to have assumed *379both the existence of a joint venture and that all employees of one party to the venture were coem-ployees of all other parties to the venture. The second assumption is not supported by Michigan law. Our Supreme Court specifically refused to answer the question in Goodwin v S A Healy Co, 383 Mich 300, 313; 174 NW2d 755 (1970), rev’g, 13 Mich App 514; 164 NW2d 693 (1968). Nor is it necessary to determine the question, on the present record, in this case.
The appropriate question is who was plaintiff’s employer? The answer to the question is determined by applying the "economic reality” test. Smith v Martindale, 81 Mich App 682; 266 NW2d 49 (1978),4 and cases cited therein. It is only where it can be determined under this test that the defendants were plaintiff’s employers or coemploy-ees that the exclusive remedy provision would bar this suit.
The present record is insufficient to make that determination. Certainly, referring only to the agreement between the municipalities, while important, will not completely answer the question. In a tort suit, as opposed to a worker’s compensation hearing, the issue of whether plaintiff was an employee of the defendants should be submitted to the jury, under proper instructions, for determination based on all the evidence.5 Goodwin v S A Healy Co, 383 Mich at 311.
The trial court erred in basing judgment on this ground.
Ill
The trial court also granted a blanket judgment *380in favor of all defendants on the basis of governmental immunity. MCL 691.1407; MSA 3.996(107).6 In Section I of the opinion we held this was improper as to those defendants in default. The immunity of the other defendants must be considered separately, although they may be classified in three groups.
(a) Liability of the municipal police departments and departments of public safety.
Plaintiff made the police departments and departments of public safety of the various municipalities separate defendants. Many of these defendants claimed below and argue on appeal that they cannot be sued as a separate entity, apart from their parent municipality.
Early in the development of the doctrine of governmental immunity the inability to raise funds, through taxation or otherwise, was one justification given for finding immunity. O’Leary v Marquette Board of Fire & Water Commissioners, 79 Mich 281; 44 NW 608; 7 LRA 170; 19 Am St R 169 (1890). Some later cases have referred to the inability to raise funds as an independent ground for nonliability without critical analysis. See, McPherson v Fitzpatrick, 63 Mich App 461; 234 NW2d 566 (1975), lv den, 399 Mich 830 (1977). However, the inability to raise funds was nothing more than one of the stated justifications for the *381doctrine of governmental immunity, not a separate immunity. Bush v Oscoda Area Schools, 72 Mich App 670, 685; 250 NW2d 759 (1976) (Opinion of W. R. Peterson, J.), lv gtd, 399 Mich 895 (1977).
The police departments and departments of public safety stand on the same footing as the municipalities themselves. There is no immunity simply because of their inability to raise funds, it rests on the same statute as the immunity of the municipalities. This is the clear import of Allen v Womack, 399 Mich 833; 250 NW2d 68 (1977), reversing a judgment in favor of the Detroit Police Department on the basis of governmental immunity.
This group of defendants is bound by the standards applicable to the municipalities set out below.
(b) Liability of the individual officers.
In granting judgment for all defendants, the trial court concluded that the individual officers were entitled to immunity under the statute. This is incorrect on these facts. The officers had an individual common-law duty to exercise due care when dealing with plaintiff. Cole v Rife, 77 Mich App 545; 258 NW2d 555 (1977).7 The statute grants no immunity to an individual for personal acts of negligence solely because he is a governmental employee. The complaint in this case is sufficient to avoid summary judgment under GCR 1963, 117.2(1) as to the individual defendants and, therefore, the judgments in favor of these defendants must be reversed.
*382The judgments in this case were granted before discovery was begun and the record does not satisfactorily explain the relationship of some of the individual officers to plaintiffs injury. After discovery is completed, it would not be inappropriate for the trial court to consider individual motions for summary judgment under GCR 1963, 117.2(3), the absence of material fact. If there is no question of material fact concerning the breach of the individual’s duty to plaintiff, i.e., if the individual is not involved with the injury, the summary judgment would be proper. However, the trial court acted prematurely in dismissing the suit against all the individual officers on the present record.
(c) Liability of the municipalities.
The most difficult question in this appeal is which, if any, of the municipal defendants were properly dismissed on the present record. It is my view that the record is insufficient to show which of this group of defendants may be responsible for the acts of the individual officers directly causing plaintiffs injury and, therefore, the appropriate action is to reverse the blanket grant of judgment for the defendants and remand for further proceedings.8 Cf. Kriger v South Oakland County Mutual Aid Pact, 399 Mich 835; 250 NW2d 67 (1977) rev’g 49 Mich App 7; 211 NW2d 228 (1973).
The body of law collectively known as "governmental immunity” is presently ever changing in an attempt to settle on a doctrine which can be *383accepted as just, both by the citizens of the state and the judges of the various courts. The recent efforts of the Supreme Court9 have done little to bring certainty to the area or to quiet the cries of injustice. We can only hope that either the Supreme Court or the Legislature act soon to correct a situation which, judging from the number of cases and the lack of uniform disposition in this Court, has resulted in much confusion. See Justice Levin’s dissent in Thomas v Dept of State Highways, 398 Mich 1, 25; 247 NW2d 530 (1976). Perhaps an answer will come with the opinion in Parker v Highland Park, lv gtd, 399 Mich 833 (1977).
Until the Supreme Court speaks with more unanimity, this Court is free to address the question on a case by case basis. In dealing with the problem, I have found the possibility of governmental liability to be dependent on the type of activity engaged in by the governmental agents and the proximity of the plaintiffs to the governmental defendant. Compare, Wojtasinski v Saginaw, 74 Mich App 476; 254 NW2d 71 (1977) (one prisoner beaten by another in a county jail) and Allen v Dept of Mental Health, 79 Mich App 170, 173; 261 NW2d 247 (1977), (T.M. Burns, J., concurring) (patient committing suicide while on temporary leave from the state defendant) with Gerzeski v Dept of State Highways, 68 Mich App 91, 101; 241 NW2d 771 (1976) (T. M. Burns, J., dissenting), rev’d, 403 Mich 149; 268 NW2d 525 (1978), White v Detroit, 74 Mich App 545, 548; 254 NW2d 572 (1977) (T. M. Burns, J., dissenting), Duncan v De*384troit, 78 Mich App 632, 634; 261 NW2d 26 (1977)10 (T. M. Burns, J., dissenting) and Brown v Detroit, 83 Mich App 342; 268 NW2d 400 (1978) (T. M. Burns, J., dissenting).
In this case, plaintiff claims he was injured when he was negligently shot in the face by a police officer. He also claims negligence in allowing rice filled shells to be used in the police training exercise. I cannot believe that either of these specific claims of negligence is in any way a governmental function. Certainly there are many situations where a private entity would be liable for such actions.
Which of the municipal defendants are responsible for these negligent acts depends on facts which can only be developed by further proceedings. It is only after the facts are developed that the relationship of the various defendants to each other and to the injured plaintiff can be determined, see section II of this opinion, and based upon those relationships which governmental units were responsible for the acts of the individual officers.
The judgments of the circuit court are reversed and the case remanded for further proceedings not inconsistent with this opinion. No costs, a public question.
The complaint also included a derivative action by Mrs. Peggy Berger. Plaintiff will be used to describe the claims of both Mr. & Mrs. Berger throughout the opinion.
Plaintiff claims that there were ten defendants in default at the time the judgments were entered. Our review of the record shows that there were defaults outstanding against the City of Pleasant Ridge and its police department, Sterling Township and its police department, Mike Mahoney, Officer Stevenson, the Chiefs of Police Association and the South Oakland Tactical Support Unit at the time the judgments were entered. The City of Sterling Heights, which was the successor to Sterling Township, had moved to have its default set aside. The trial court has never passed on this motion and the motion to set aside should be decided before a default judgment is entered against Sterling Heights.
Only the police departments and Cities of Ferndale, Huntington 1Woods, Madison Heights, Troy and Beverly Hills and several individuals relied on this ground below.
In Nichol v Billot, 80 Mich App 263; 263 NW2d 345 (1977), lv gtd, 402 Mich 922 (1978), the panel held that in a tort suit the "control” test was still the appropriate test. We believe the weight of authority requires application of the economic reality test in tort suits also.
This issue would be for the court only if there are no disputed facts. Smith v Martindale, supra.
With the demise of common-law governmental immunity for the ■ state and its agencies in Pittman v City of Taylor, 398 Mich 41; 247 NW2d 512 (1976), all immunity in this state is statutory. The present statute provides: "Except as in this act otherwise provided, all governmental agencies shall be immune from tort liability in all cases wherein the government agency is engaged in the exercise or discharge of a governmental function. Except as otherwise provided herein, this act shall not be construed as modifying or restricting the immunity of the state from tort liability as it existed heretofor, which immunity is affirmed.” MCL 691.1407; MSA 3.996(107).
Cole drew support from Lovitt v Concord School District, 58 Mich App 593; 228 NW2d 479 (1975). Lovitt was criticized by Justice Williams in his opinion in Galli v Kirkeby, 398 Mich 527, 536; 248 NW2d 149 (1976), and cited with approval by Justice Coleman in her opinion in the same case. 398 Mich at 544.
For example, the City of Bingham Farms claims that it is not a member of the mutual aid pact and had no officers present at the training exercise. Apparently, the City of Bingham Farms has no police force at all. An individual motion for summary judgment based on the absence of any material fact would be appropriate after the remand.
Thomas v Dept of State Highways, 398 Mich 1; 247 NW2d 530 (1976), Pittman v City of Taylor, 398 Mich 41; 247 NW2d 512 (1976), McCann v Michigan, 398 Mich 65; 247 NW2d 521 (1976), and Galli v Kirkeby, 398 Mich 527; 248 NW2d 149 (1976).
Application for leave to appeal in White and Duncan has been held in abeyance pending disposition of Parker v Highland Park.