Griebel v. Industrial Commission of Arizona

Walter H. Griebel worked for Kathleen Rector (defendant) and Mrs. Rector’s late husband as a handyman on the Rectors’ ranch, Morning Star. After Mr. Rector died, Mrs. Rector moved to a townhouse in the city. Mrs. Rector was a wealthy woman who had no trade, business, or occupation, and she had no plans to sell Morning Star ranch or any other property. Griebel assisted Mrs. Rector with her move and continued to work as a handyman at the Morning Star ranch after Mr. Rector’s death. Griebel also occasionally helped with the maintenance of other Rector properties. Mrs. Rector became engaged to Mr. Dayton, and Dayton asked Griebel to help with an electrical problem on an old ranch on a leased mining claim. Dayton owned the old ranch, but purely for personal use, because the property was not suitable for a commercial enterprise. Griebel was killed in a car accident while traveling between Morning Star ranch and either Mrs. Rector’s townhouse or Dayton’s ranch. Griebel’s widow, Eleanor Griebel (plaintiff), filed a claim for workers’-compensation death benefits. The Industrial Commission of Arizona (defendant) found that Mrs. Rector was not engaged in a trade, business, profession, or occupation and that Griebel was a domestic servant. Accordingly, the Arizona statute exempting domestic servants from workers’-compensation coverage applied, and the Industrial Commission denied Mrs. Griebel’s claim. Mrs. Griebel appealed, arguing that Mrs. Rector was in the business of owning properties for their appreciating values, and Griebel was not a housekeeper or maid and, therefore, not a domestic servant.