44 A.3d 1241
R.I.2012Background
- Plaintiff Sean LaFreniere, passenger in defendant's Ford F350, sustained injuries in a collision in Ohio on August 3, 2007.
- The vehicle was owned by Dutton, used for his landscaping business, and insured by Metropolitan; business logo on the truck.
- Plaintiff later received approximately $41,000 in workers' compensation benefits from Beacon for injuries arising from the accident.
- Defendant moved for summary judgment premised on exclusivity of workers' compensation under § 28-29-20, alleging plaintiff's injuries were work-related and that Dutton was plaintiff's employer.
- Trial court granted summary judgment, deeming plaintiff precluded from tort recovery; plaintiff appealed.
- Rhode Island Supreme Court reviews de novo and affirms, holding defendant was plaintiff's employer and the exclusivity provision bars a common-law negligence claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exclusivity bars tort claims here | LaFreniere argues exclusivity prevents any tort claim since WC benefits were collected. | Dutton argues WC exclusivity applies because LaFreniere was his employee and benefits were paid by Beacon. | Yes; exclusivity bars the tort claim. |
| Whether Dutton was the plaintiff's employer under § 28-29-2(5) | LaFreniere contends Dutton was not an employer of the plaintiff. | Dutton contends he is the sole proprietor of M.P. Dutton Landscaping and thus the employer. | Yes; Dutton was plaintiff's employer. |
| Whether the trip to Ohio was for personal reasons and defeats exclusivity | LaFreniere asserts the trip was personal and not work-related for purposes of WC exclusivity. | Dutton argues the trip was work-related and that the WC benefits apply regardless of personal vs. business purpose at the time of the collision. | No; the trip's purpose does not defeat exclusivity given employer status and WC benefits. |
Key Cases Cited
- Laliberte v. Salum, 503 A.2d 510 (Rh. 1986) (owner of sole proprietorship not separate from the company)
- Manzi v. State, 687 A.2d 461 (Rh.1997) (exclusivity bars recovery on different legal theories for same injuries)
- Kulawas v. Rhode Island Hospital, 994 A.2d 649 (Rh.2010) (exclusivity context and allocation of fault not at issue)
- Sorenson v. Colibri Corp., 650 A.2d 125 (Rh.1994) (act curtails litigation and relinquishment of common-law rights)
- DiQuinzio v. Panciera Lease Co., 612 A.2d 40 (Rh.1992) (WC benefits require relinquishing common-law remedies)