Catherine Lyons v. Chittenden Central Supervisory Union
185 A.3d 551
Vt.2018Background
- Catherine Lyons, an experienced teacher, enrolled in UVEI's two-semester internship to satisfy Vermont student-teaching and licensure requirements and paid tuition/placement fees to UVEI.
- UVEI placed Lyons at a Chittenden Central Supervisory Union (CCSU) kindergarten classroom under a written placement agreement; Lyons performed classroom duties, attended meetings, had school ID/email/keys, but received no monetary wages from CCSU and could not create official student records.
- Lyons was injured in a slip-and-fall while student teaching and filed a workers' compensation claim; the insurer and CCSU denied coverage.
- The Department of Labor Commissioner granted summary judgment for CCSU, reasoning that without wages (monetary or valuably-quantified advantages from the employer) there is no employment relationship for workers’ compensation purposes.
- The Vermont Supreme Court reversed and remanded, holding Lyons falls within the statutory definition of employee because (1) the placement was a contract for service/apprenticeship, (2) she received "remuneration" in the form of a valuable advantage (student-teaching toward licensure), and (3) where an advantage equates directly to obtaining a professional license its value can be estimated in money as a matter of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lyons was an "employee" under 21 V.S.A. § 601(14) | Lyons: She worked under a contract of service/apprenticeship and thus is a statutory employee entitled to benefits. | CCSU: Lyons was an unpaid trainee/student; absence of wages means no employment relationship. | Court: Lyons is a statutory employee (contract for service/apprenticeship present); remanded to determine benefits. |
| Whether non‑monetary "advantages" (training/licensure opportunity) constitute "wages" under § 601(13) | Lyons: The student-teaching placement is remuneration; the value of the licensure opportunity can be estimated in money. | CCSU: Any benefit was unquantifiable, conferred by UVEI/state, not CCSU, so not "wages." | Court: The placement was an "other advantage" and, because it directly enabled a professional license, its value can be estimated in money as a matter of law. |
| Whether parties' subjective intent (to create employment) controls valuation/coverage | Lyons: Not necessary; statutory definitions control; objective factors suffice. | CCSU: Parties did not intend employment; that intent should be dispositive. | Court: Intent is not the statutory test; valuation and statutory definitions govern, not parties' intent. |
| Whether summary judgment was appropriate without factual valuation evidence | Lyons: Value can be determined as matter of law here due to direct tie to licensure. | CCSU: Valuation requires fact development; summary judgment improper. | Court: Because internship directly equated to licensure, value is estimable as a matter of law; summary judgment reversed and case remanded to compute benefits. |
Key Cases Cited
- DeBartolo v. Underwriters at Lloyd's of London, 181 Vt. 609 (Vt. 2007) (standard of review for summary judgment and de novo review explanation)
- Letourneau v. A.N. Deringer/Wausau Ins. Co., 184 Vt. 422 (Vt. 2008) (deference to Commissioner administering workers' compensation)
- Lydy v. Trustaff, Inc./Wausau Ins. Co., 194 Vt. 165 (Vt. 2013) (definition of remuneration as payment for services; nonmonetary forms may qualify)
- Wolfe v. Yudichak, 153 Vt. 235 (Vt. 1989) (no indemnity where claimant received no wages; limits on compensability without wage replacement)
- Haller v. Champlain College, 177 A.3d 497 (Vt. 2017) ("other advantages" can be wages where market value is discernible; valuation focuses on employee's benefit)
- Montgomery v. Brinver Corp., 142 Vt. 461 (Vt. 1983) (workers' compensation statutes remedial; liberally construed)
- Betts v. Ann Arbor Pub. Schs., 271 N.W.2d 498 (Mich. 1978) (student teacher held employee where training/credits met prerequisites for certification and benefited employer)
- Walls v. North Mississippi Med. Ctr., 568 So.2d 712 (Miss. 1990) (student nurse treated as apprentice/employee when clinical training conferred licensure-related benefits)
- O'Brien v. O'Brien, 498 N.Y.S.2d 743 (N.Y. 1985) (framework for valuing professional licensure as an asset; present-value earning-capacity approach)