Pruitt v. State
1 CA-CV 24-0418
Ariz. Ct. App.May 25, 2025Background
- David Lee Pruitt was employed by Televerde as a civilian supervisor at a call center operated within Perryville State Prison, under contract with the Arizona Department of Corrections, Rehabilitation and Reentry (ADCRR).
- While supervising inmates at the prison, Pruitt was injured after stepping in a pothole, and he received workers’ compensation benefits from Televerde.
- Pruitt subsequently filed a tort suit against the State of Arizona and ADCRR for negligence, premises liability, and negligent hiring.
- The State moved for summary judgment, arguing it was Pruitt's statutory employer under A.R.S. § 23-902, granting it immunity from tort claims.
- The trial court granted summary judgment for the State and denied Pruitt’s motion for a new trial; Pruitt appealed both rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State is Pruitt’s statutory employer | The contract was only between ADCRR and Televerde, not the State; thus, the State cannot be the statutory employer | ADCRR is legally an arm of the State, and the contract is effectively with the State, making it the statutory employer | State is statutory employer; court affirms summary judgment |
| Whether ADCRR retained necessary control/supervision over Televerde’s work | ADCRR did not supervise or control the for-profit call center operations of Televerde | The State retained control through contract provisions including approval of hires, background checks, facility and procedure controls | State had sufficient supervision; summary judgment appropriate |
| Whether the work assigned to Televerde was a “part or process in the trade or business” of ADCRR | Operating a call center is not part of ADCRR’s core correctional business | Providing inmate rehabilitation/employment is a statutory part of ADCRR’s business | Work was part of ADCRR’s business; summary judgment affirmed |
| Whether denial of a new trial was an abuse of discretion | Denial based on misapplication of the statutory employer doctrine; deprived Pruitt of a fair trial | Court properly applied the law; summary judgment was correct | No abuse of discretion; denial of new trial upheld |
Key Cases Cited
- Young v. Environmental Air Products, Inc., 136 Ariz. 158 (elements for statutory employer status)
- Hunt Building Corp. v. Industrial Commission, 148 Ariz. 102 (control needed for statutory employer status)
- Home Insurance Co. v. Industrial Commission, 123 Ariz. 348 (factors for determining employment relationship)
- Smith v. Melson, Inc., 135 Ariz. 119 (construction of unambiguous contracts as a legal question)
- Livingston v. Citizen's Utilities, Inc., 107 Ariz. 62 (distinguishing cases without express contracts)