Bruley v. Fonda Group, Inc.

Dooley, J.,

dissenting. The majority opinion is based on a distinction without a difference. The holding in Wlock v. Fort Dummer Mills, 98 Vt. 449, 129 A. 311 (1925), applied the settled doctrine that “the provisions of the Workmen’s Compensation Acts are inapplicable in cases where personal injuries have been suffered by a minor whose employment was unlawful.” Id. at 458, 129 A. at 314. Illegality is a matter of contract law. Where illegality is based on a violation of statutory law, the statute can be state or federal. See Restatement (Second) of *5Contracts § 178 comment a (1981). Thus, it makes no difference whether the employment is illegal under the Vermont Child Labor Law or the federal Fair Labor Standards Act, as long as it is illegal.

The decision in Wisell v. Jorgensen, 136 Vt. 604, 398 A.2d 283 (1979), is not consistent with the majority opinion. It reaffirms that Wlock allows the minor to sue the employer “where the contract of employment was illegal.” Id. at 605, 398 A.2d at 284. It found Wlock inapplicable because no statute “makes it unlawful for a person with a junior operator’s license to be employed as a repairman or test driver of motorcycles.” Id. In other words, the statute relied upon by plaintiff was a motor vehicle statute, not an employment statute. Plaintiffs here rely on an employment statute that makes unlawful the employment of a minor in an occupation involving the operation of power-driven machinery. This case is like Wlock and not like Wisell.

Whether state or federal:

The child labor laws ... are premised in part on the notion that a child is not competent to assess the risks of personal injury and exploitation attendant in the performance of hazardous activities. Where one party to an agreement possesses a legal disability of this type, we will not permit the other, who occupies a superior bargaining position, to raise the agreement as a shield against the child’s common law suit.

Whitney-Fidalgo Seafoods, Inc. v. Beukers, 554 P.2d 250, 253 (Alaska 1976). The long-term trend is that state protective labor laws are preempted by federal ones so as to create uniform standards. The public policy of this state should continue to be protective of the options of minors, even if the specific statute involved is federal. To the extent this decision turns on an insular view of statutory turf rather than the dominant public purpose, it is the beneficiaries of protective labor laws who are the losers.

The majority expresses concern that allowing the plaintiffs to pursue the common-law remedy here will make other minors ineligible for workers’ compensation, although it acknowledges that minors could be allowed to elect the desired remedy. Allowing an election is consistent with the theory of the Wlock doctrine and is not an extension of that case. See Whitney-Fidalgo *6Seafoods, Inc. v. Beukers, 554 P.2d at 253-54; Blancato v. Feldspar Corp., 203 Conn. 34, 41-42, 522 A.2d 1235, 1239 (1987). Doing justice for these plaintiffs does not require us to work an injustice on others.

I dissent.