Olvera v. Del's Auto Body

BISTLINE, Justice,

dissenting.

While I agree that the appropriate standard of review requires this Court to leave undisturbed factual findings of the Industrial Commission which are supported by substantial and competent evidence, this standard does not inevitably always lead to an affirmance. In this case, if we consider the facts as they were found by the referee and as they were adopted by the Industrial Commission, and apply the law of Idaho to those facts, the inevitable result is a finding, as a matter of law, that Hector Olvera was a covered employee and not an independent contractor of Del’s Auto Body when he was injured.

The questions of fact that must be answered before a worker may be treated (for the purposes of workers’ compensation) as an independent contractor have been discussed by this Court before:

The ultimate question in finding an employment relationship is whether the employer assumes the right to control the time, manner and method of executing the work of the employee, as distinguished from the right merely to require certain definite results in conformity with their agreement. [Citations omitted.] Four factors are traditionally used in determining whether a “right to control” exists, including, (1) direct evidence of the right; (2) the method of payment; (3) furnishing major items of equipment; and (4) the right to terminate the employment relationship at will and without liability.

Burdick v. Thornton, 109 Idaho 869, 871, 712 P.2d 570, 572 (1985). Of the four factors indicating a right to control, only the first is concerned with direct evidence. The other three involve indirect evidence which may or may not raise the inference of a right to control. I will consider each factor in reverse order.

Did Olvera have the right to terminate the employment relationship at will and without liability? Olvera testified that he did indeed; but the owners of Del’s Auto Body said that this right was restricted, in that Olvera would only be allowed to walk away when the present job or project had been completed. On the other hand, however, no restrictions were placed on the right of Del’s to terminate the relationship at will without liability. This lack of mutuality strongly suggests that Olvera was not an independent contractor, but that the relationship was one of employment terminable at will.

Did Del’s Auto Body furnish major items of equipment? Del’s Auto Body not only furnished the work area, but it also furnished the air compressor to be used by the workers in the auto body shop. Olvera supplied his own paint guns, but that fact is not inconsistent with an employee-employer relationship. Most if not practically all car mechanics must bring their own tools to work, and this matter of employee-owned hand tools is prevalent in other industries, and is a matter of common knowledge.

Did the method of payment suggest that Olvera was an independent contractor? *167Del’s Auto Body paid Olvera sixty percent of the bid for labor charges given to the customer by Del’s for the work to be performed. While this is more than what Olvera received for work at other shops he had worked at in the past, that fact alone may simply indicate that Olvera was a valuable employee.

No taxes were deducted from the payments made to Olvera. While this fact might tend to indicate Olvera’s understanding that Del’s was treating him as an independent contractor, and hence not covered by workers’ compensation, there are conflicting facts. Of significance, and required by law, on the wall in Del’s office was the Commission’s printed notice that Del’s was in compliance with I.C. § 72-301 of the Act. Failure to post the Notice and keep it posted amounts to a misdemeanor. Olvera maintains that he was never warned — in writing or verbally — that he was considered by Del’s Auto Body to be not covered by the Act and that the Notice had no application to him.

In addition, I.C. § 72-318(1) affirmatively states that “[n]o agreement by an employee to pay any portion of the premiums paid by his employer for workmen’s compensation ... shall be valid.” Subsection (2) of the same statute states that “[n]o agreement by an employee to waive his rights to compensation under this act shall be valid.” The appeal record contains no such agreement in writing between Del’s and Olvera. The statute itself does not state “in writing.” However, the statute would be meaningless if an employer, putative or actual, could invoke an oral agreement. While the whole question here is whether Olvera is an employee or not, I.C. § 72-318 at least suggests that a determination of the real nature of the employment relationship should come before any reliance is heavily placed upon the method of payment or the method of deduction.

Did Olvera establish direct evidence of Del’s right to control his employment? As stated before, no written agreement between the parties was made. Olvera asserts that he was told to come in and work from 8 a.m. to 5 p.m., and the owners of Del’s testified that Olvera worked “radical” hours. This suggests that Olvera was indeed asked by Del’s to work “normal” hours. The manner and method of work was dictated by Olvera, because Del’s relied upon Olvera’s expertise. Nevertheless, Del’s bid the work, and estimated how long Olvera would need to perform the job.

In sum, the direct evidence of Del’s right to control Olvera is not determinative of the issue, and the indirect evidence of the right to control (i.e., method of payment, furnishing equipment, and right to terminate) points in the direction of finding, as a matter of law, that Olvera is a covered employee. But the analysis may not end there.

As this Court has recognized, the Workers’ Compensation Act should be liberally construed in favor of the employee, and in favor of coverage instead of exemption from coverage:

The statutory basis for the principle of liberal construction of the workers’ compensation laws in favor of claimants is I.C. § 72-201 (1989). This declaration of the purpose of the workers’ compensation system in Idaho states that “sure and certain relief for injured workmen and their families and dependents is hereby provided regardless of questions of fault as is otherwise provided in this act.”
For almost seventy years this Court has adhered to the principle that the workers’ compensation law should be liberally construed in favor of the claimant in order to effect the object of the law and to promote justice. [Citations omitted.]

Haldiman v. American Fine Foods, 117 Idaho 955, 793 P.2d 187 (1990). This principle was echoed in Burdick v. Thornton, 109 Idaho 869, 712 P.2d 570 (1985). After announcing the test for independent contractor status, the Court wrote:

We note that evidence in this case was conflicting and that circumstances surrounding this relationship could easily be argued as establishing an employment or independent contractor relationship. However, when a doubt exists as to *168whether an individual is an employee or an independent contractor under the Workmen’s Compensation Act, the Act must be given a liberal construction in favor of finding the relationship of employer and employee.

Burdick, 109 Idaho at 871, 712 P.2d at 572 (citation omitted) (emphasis added).

Taken together, the principle of liberal interpretation in conjunction with a sober look at the facts of this case inevitably leads to the conclusion that Olvera is a covered employee. There is another reason for finding coverage, prospective in nature, that this Court should have addressed. In Bon Appetit Gourmet Foods v. Idaho, 117 Idaho 1002, 793 P.2d 675 (1989), this Court affirmed its holding that provisions of I.C. § 72-1316(d) were unconstitutional, because they required employers to pay unemployment compensation for certain independent contractors. What today’s decision and Bon Appetit in aggregate amount to is a statement that the presumption of coverage has vanished. This Court will no longer presume coverage until the facts affirmatively show otherwise.