Norton v. Boyle

Summary

The Rhode Island Supreme Court reviewed a judgment as a matter of law in favor of Russell J. Boyle in an employee's personal-injury action. The court held that uncontradicted evidence established Boyle was acting as an agent of the funeral home when he moved a limousine during funeral proceedings, making workers' compensation the employee's exclusive remedy. The court denied the appeal and affirmed the judgment.

Holdings

1. The evidence, viewed in the light most favorable to Norton, unequivocally established that Boyle was acting as an agent of the funeral home when he moved the limousine during the funeral.
2. Judgment as a matter of law was proper because the evidence permitted only one legitimate conclusion: Boyle was an agent of the funeral home when the accident occurred.
3. The court did not decide whether the statutory presumption of agency under § 31-33-6 applied because the evidence independently established Boyle's agency status.

Questions Presented

1. Whether the evidence conclusively established that Boyle was acting as an agent of the funeral home when he moved the limousine and injured Norton.
2. Whether the trial justice properly granted judgment as a matter of law rather than submitting Boyle's agency and scope of authority to the jury.
3. Whether the statutory presumption of agency under G.L. 1956 § 31-33-6 applied to Boyle's operation of the vehicle.

Disposition

affirmed