Standring v. Town of Skowhegan

RUDMAN, J.,

with whom CLIFFORD, J. joins, concurring.

[¶ 16] Although I concur in the Court’s decision to vacate the decision of the hearing officer, I do so because the hearing officer did not consider all of the factors that should be considered in determining whether Standring’s injury was connected to his employment.

[¶ 17] The facts in this case are not in dispute. The hearing officer found that Standring, “a fifty-two year old Waterville resident, worked for [the Town of Skowhe-gan] as a reserve police officer.” The hearing officer further noted “[t]here is no dispute that [Standring] suffered a heart attack while running during the PAT conducted on August 30, 2002, or that he notified [the Town] of this injury in a timely manner.”

[¶ 18] The hearing officer correctly noted that her job was to “determine whether an applicant for a job who participates in a physical [agility] test as part of an employer’s application process, is an ‘employee’ entitled to the protection of the Workers’ Compensation Act.”

[¶ 19] The Court correctly notes that “the workers’ compensation law provides that when an employee ‘receives a personal injury arising out of and in the course of employment’ ” the employee is entitled to be paid compensation and furnished with medical and other services by the employer. 39-A M.R.S.A. § 201(1) (2001). The issue before us is whether an injury sustained by a person employed by the employer in a different capacity during a tryout for another position is compensable as a job-related accident.

[¶ 20] Although there are cases to the contrary,4 the more recent view adopted in Younger v. City and County of Denver, 810 P.2d 647 (Colo.1991), outlines some of the factors which should be considered when determining whether a job applicant is entitled to the benefits of the Workers’ Compensation Act. Younger voluntarily applied for a position as a police officer. Id. at 653. She was neither encouraged to pursue this position nor was she paid for her participation in the application process. Id. She was taking the test for her own benefit so that she would be eligible for employment. Had Younger successfully completed the physical agility test she would have still been required to pass background checks, polygraph tests, and a medical" examination merely to qualify from the pool of candidates from which the final selection of police officers would be made. Id. The Colorado court concluded that there was no mutual agreement between the City of Denver and Younger *133sufficient to create an employer-employee relationship that would justify an award of workers’ compensation benefits. Id.

[¶ 21] The language of our statute unambiguously indicates that workers’ compensation benefits arise directly from the contractual relationship between employer and employee pursuant to which the employee was performing the service resulting in his/her injury.5 Not all applicants injured during a pre-employment physical agility test are entitled to compensation, otherwise “every person who makes application to an employer for a job, fills out an application and takes any kind of test is ipso facto an employee.” Dykes v. State Accident Ins. Fund, 47 Or.App. 187, 613 P.2d 1106, 1107 (1980). Such is not the law in Maine.

[¶ 22] Moreover, while a “contract for hire” may be express or implied, written or oral, it must always be consensual. “To thrust upon a worker an employee status to which he or she has never consented ... might well deprive him or her of valuable rights under the compensation act, notably the right to sue his or her own employer for common-law damages.” 3 AsthuR LawsoN & Lex K. Larson, Larson’s WorKers’ Compensation Law § 64.01 at 64-3 (2004).

[¶ 23] The hearing officer acknowledged Standring’s relationship with the Town. Prior to voluntarily taking the test, Standring was a reserve officer. No one disputes that Stanching had been employed by the Town in that capacity. There is no dispute that 39-A M.R.S.A. § 201(1) provides that “an employee” who “receives a personal injury arising out of and in the course of employment” is entitled to compensation benefits. In her opinion, the hearing officer appears to con-fíate the issues. First, she states that “the primary issue in this case is whether [Standring’s] heart attack arose out of and in the course of his work for [the Town]” and then concludes there was no contract of employment.

[¶24] I would vacate the decision of the hearing officer and remand for her to determine, pursuant to the factors considered by the Colorado court in Younger, whether the employment relationship between Standring and the Town was sufficiently related to the full-time police officer position for which Standring was applying, so that Standring’s injury can be said to arise out of and in the course of his employment.

. See, e.g., Laeng v. Workmen’s Comp. Appeals Bd.., 6 Cal.3d 771, 100 Cal.Rptr. 377, 494 P.2d 1 (1972); Smith v. Venezian Lamp Co., 5 A.D.2d 12, 168 N.Y.S.2d 764 (1957).

. " 'Employee' includes ... every person in the service of another under any contract of hire, express or implied, oral or written....” 39-A M.R.S.A. § 102(11) (2001) (emphasis added).