Uninsured Employers' Fund v. Tyson Farms, 220 A.3d 429

Mauro Jimenez Garcia was the resident manager of a broiler (chicken) farm; he lived on the farm 24/7 and performed day-to-day husbandry work.
Dai K. Nguyen owned the farm as an absentee owner and contracted with Tyson Farms under a Broiler Production Contract; Tyson retained title to chickens, feed, and medication.
The contract required adherence to detailed Tyson guidance (an 18‑page Broiler Growing Guide), gave Tyson technical/veterinary services, frequent inspections (1–3x/week), training of Garcia, and a unilateral right to terminate and take possession of chickens on default.
Garcia developed an occupational lung disease on April 15, 2014; the Workers’ Compensation Commission found both Nguyen and Tyson to be co‑employers; Tyson appealed to circuit court and a jury found Tyson was not a co‑employer.
The Uninsured Employers’ Fund (UEF) appealed the denial of its motion for judgment; the Court of Special Appeals held as a matter of law that Tyson was Garcia’s co‑employer and reversed the circuit court.

Issue	Plaintiff's Argument (UEF)	Defendant's Argument (Tyson)	Held
Whether Tyson was a co‑employer of Garcia for workers’ compensation purposes	Tyson exercised decisive control over Garcia’s work (training, detailed directives, frequent inspections, provided feed and protocols, right to terminate on default), so employer as matter of law	Tyson had only limited supervision of the farm and chickens; Nguyen hired/paid/fired Garcia and set hours; Tyson controlled the flock, not the worker — factual dispute for jury	Reversed circuit court: Tyson was a co‑employer as a matter of law because the control factor was satisfied by undisputed facts (detailed guide, training, frequent oversight, and termination power)

Whitehead v. Safway Steel Products, Inc., 304 Md. 67 (Md. 1985) (when evidence is undisputed and conflicting inferences are not possible, the court may decide employer status as a matter of law; otherwise jury decides)
Mackall v. Zayre Corp., 293 Md. 221 (Md. 1982) (five‑factor test for employer–employee relationships; control is the decisive factor)
Great Atl. & Pac. Tea Co. v. Imbraguglio, 346 Md. 573 (Md. 1997) (in multi‑party cases employer/employee status is often a fact issue; court cannot grant summary judgment when evidence cuts both ways)
North Chesapeake Beach Land & Imp. Co. v. Cochran, 156 Md. 524 (Md. 1929) (mere supervision or contractual inspection rights do not automatically create an employment relationship)
Marcus v. Eastern Agricultural Ass’n, Inc., 32 N.J. 460 (N.J. 1960) (even where farm work is routine, factors like economic dependence and relationship to the employer’s business can support employee status)
McElroy Truck Lines, Inc. v. Pohopek, 375 Md. 574 (Md. 2003) (where essential terms and manner of employment are undisputed, the relationship can be decided as a question of law)