Billy Etheridge v. JJ Curran Crane Company, 356775

Defendant JJ Curran Crane rented cranes with operators to Ferraro Pile & Shoring under a Crane Rental & Operator Agreement for a Detroit seawall project; defendant acted as a labor broker.
Defendant provided operator Ryan Blake and paid his wages; Ferraro paid defendant for Blake’s hours and supervised day-to-day work.
Daily crane tickets and the Agreement contained provisions stating the crane operator would be "under [Ferraro]’s exclusive direction and control" and would be Ferraro’s "agent, servant, and employee."
On October 29, 2018, Blake’s crane operation caused a suspended metal piece to crush plaintiff Billy Etheridge’s hand; Etheridge sued defendant for negligence, alleging Blake was defendant’s employee.
Defendant moved for summary disposition under MCR 2.116(C)(10), arguing the WDCA’s exclusive-remedy provision barred Etheridge’s suit because Blake was a Ferraro employee; the trial court agreed and entered judgment for defendant.
On appeal, the Court of Appeals affirmed, applying the economic-reality test and concluding no genuine factual dispute that Blake was Ferraro’s employee, so the WDCA was the exclusive remedy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Blake was an employee of Ferraro under the economic-reality test, such that the WDCA’s exclusive-remedy provision bars Etheridge’s negligence suit against JJ Curran Crane	Etheridge: reasonable minds could differ under the economic-reality factors, so a question of fact exists about who employed Blake	JJ Curran: evidence shows Ferraro controlled Blake’s duties, paid for his labor (through defendant), had discipline/hire authority, and Blake worked toward Ferraro’s project goals; thus Ferraro was the employer and WDCA bars suit	Court: No genuine issue of material fact — applying the economic-reality test (control, payment, hire/fire/discipline, integral part/common goal) Blake was Ferraro’s employee; WDCA is exclusive remedy and summary disposition for defendant affirmed

Clark v United Technologies Auto, Inc., 459 Mich 681 (defines the economic-reality test and when employment is a question of law vs. fact)
Kidder v Miller-Davis Co., 455 Mich 25 (labor-broker context can create shared-employer status under the WDCA)
Farrell v Dearborn Mfg Co., 416 Mich 267 (describes labor-broker relationships and their effect on control and employer status)
Pro-Staffers, Inc. v Premier Mfg Support Servs, Inc., 252 Mich App 318 (explains WDCA exclusive-remedy limits employer negligence exposure)
West v General Motors Corp., 469 Mich 177 (standard for summary disposition)