Sean LaFreniere et al. v. Michael P. Dutton et al.

Summary

The Rhode Island Supreme Court affirmed summary judgment for Michael P. Dutton in a negligence action arising from a motor-vehicle collision involving an employee. The court held that the plaintiff's receipt of workers' compensation benefits invoked the Workers' Compensation Act's exclusivity provision and barred a tort action against Dutton, the sole proprietor and plaintiff's employer.

Holdings

1. Dutton was LaFreniere's employer because he was the sole proprietor of M.P. Dutton Landscaping and paid LaFreniere wages to accompany him on the trip.
2. LaFreniere's acceptance of approximately $41,000 in workers' compensation benefits relinquished his right to sue Dutton in tort for the same injuries.
3. Summary judgment for Dutton was proper because no genuine issue of material fact affected the application of the Workers' Compensation Act's exclusivity provision, and Dutton was entitled to judgment as a matter of law.

Questions Presented

1. Whether Dutton was LaFreniere's employer for purposes of the Workers' Compensation Act because Dutton was the sole proprietor of the landscaping business.
2. Whether LaFreniere's acceptance of workers' compensation benefits barred his tort action against Dutton under the Workers' Compensation Act's exclusivity provision.
3. Whether summary judgment was proper when LaFreniere argued that the trip was undertaken for personal reasons and that Dutton did not qualify for statutory protection.

Disposition

affirmed