Pruitt v. State
1 CA-CV 24-0418
Ariz. Ct. App.May 6, 2025Background
- David Lee Pruitt worked for Televerde, supervising inmates at an ADCRR (Arizona Department of Corrections, Rehabilitation and Reentry) call center inside Perryville State Prison.
- Pruitt, a civilian, was injured on prison property while escorting inmates and received workers’ compensation benefits from Televerde.
- Pruitt sued the State of Arizona and ADCRR for negligence, premises liability, and negligent hiring/training.
- The State moved for summary judgment, arguing it was immune as Pruitt’s "statutory employer" under Arizona’s workers’ compensation law. The court granted summary judgment for the State and denied Pruitt’s motion for a new trial.
- Pruitt appealed, arguing the State was not his statutory employer because the only contract was between ADCRR and Televerde.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the State Pruitt’s statutory employer? | State not a party to employment contract, so not a statutory employer | ADCRR is an arm of the State, so contract is with the State | Yes |
| Did the State/ADCRR retain sufficient control over Televerde? | No meaningful control over Televerde’s call center operations | Contract ensured ADCRR had supervision/control over contractor's activities | Yes |
| Was the work a 'part or process' of ADCRR’s business? | Televerde’s for-profit call center not part of ADCRR’s core mission | Providing inmate rehabilitation through employment is a statutory duty | Yes |
| Did the trial court err in denying new trial? | Error in finding statutory employer; deprived Pruitt of fair trial | No error; court correctly applied law and had evidentiary support | No |
Key Cases Cited
- Young v. Environmental Air Products, Inc., 136 Ariz. 158 (Ariz. 1983) (sets two-prong test for statutory employment: control/supervision and part/process of business)
- Andrews v. Blake, 205 Ariz. 236 (Ariz. 2003) (summary judgment standard; facts viewed favorably to non-movant)
- Home Insurance Co. v. Industrial Commission, 123 Ariz. 348 (Ariz. 1979) (lists factors for determining employment relationship)
- Wagner v. State, 242 Ariz. 95 (Ariz. App. 2017) (State as statutory employer in prison contractor context)
- Mitchell v. Gamble, 207 Ariz. 364 (Ariz. App. 2004) (questions of statutory employer status reviewed de novo)