Lassiter v. Robeson Cnty. Sheriff's Dep't

Summary

The Supreme Court of North Carolina clarifies the distinction between the joint employment and lent employee doctrines under the North Carolina Workers’ Compensation Act. It holds that although an implied employment contract existed between the injured law enforcement officer and Truesdell Corporation, Truesdell did not exercise sufficient control over the officer to qualify as a joint employer. The court therefore holds that the Robeson County Sheriff’s Office was the officer’s sole employer and reverses the Court of Appeals in part.

Holdings

1. The joint employment doctrine and the lent employee doctrine are related but distinct doctrines. The joint employment doctrine requires that the employee work under the simultaneous control of two employers and that the services for each employer be the same as or closely related to those for the other; the lent employee doctrine requires that the work be essentially that of the special employer.
2. Lassiter established an implied contract for hire with Truesdell.
3. A joint employment relationship requires simultaneous control by both employers, and the decisive inquiry is whether the alleged employer had the right to control or direct the details of the employee's work, including its manner of performance. Truesdell did not exercise sufficient control over Lassiter to be a joint employer.
4. Lassiter satisfied the joint employment doctrine's nature-of-the-work requirement because his traffic-control services were the same as or closely related to his law-enforcement duties and furthered Truesdell's road-repair project.

Questions Presented

1. Whether the North Carolina joint employment doctrine is distinct from the lent employee doctrine and requires a different nature-of-the-work inquiry.
2. Whether Lassiter had an implied contract for hire with Truesdell.
3. Whether Truesdell exercised sufficient simultaneous control over Lassiter to qualify as his joint employer under the Workers' Compensation Act.
4. Whether Lassiter's traffic-control services were the same as or closely related to the services he performed for the Sheriff's Office.

Disposition

reversed