Carbajal v. Precision Builders, Inc.

Summary

The Oklahoma Supreme Court held that Andres Carbajal was an employee of Precision Builders, Inc., rather than an independent contractor, for purposes of workers' compensation jurisdiction. Applying the factors from Page v. Hardy, the Court emphasized Precision's control over Carbajal's work, provision of tools, hourly pay, and direction of travel between job sites. The Court vacated the Court of Civil Appeals opinion and the Workers' Compensation Court review-panel order and remanded for further proceedings.

Holdings

1. Whether a workers' compensation claimant was an employee or an independent contractor is a jurisdictional issue subject to de novo review.
2. Applying the Page v. Hardy factors, Carbajal was an employee rather than an independent contractor when he was allegedly injured.
3. The claimant met his burden to establish employee status by a preponderance of the evidence.

Questions Presented

1. Whether Carbajal was an employee of Precision Builders or an independent contractor for purposes of workers' compensation jurisdiction.
2. Whether the Workers' Compensation Court's employment-status determination was subject to deferential review under the any-competent-evidence standard or de novo review.
3. Whether the evidence, evaluated under the applicable employee-independent-contractor factors, established Carbajal's employee status.

Disposition

reversed_and_remanded