JFC Temps, Inc. v. Workers' Compensation Appeal Board (Lindsay)

680 A.2d 862, 545 Pa. 149 (1996)

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JFC Temps, Inc. v. Workers’ Compensation Appeal Board (Lindsay)

Pennsylvania Supreme Court
680 A.2d 862, 545 Pa. 149 (1996)

Facts

Alonzo Lindsay (plaintiff) was hired by JFC Temps, Inc. (JFC) (defendant) and assigned to G&B Packing (G&B) (defendant) as a tractor-trailer driver. Lindsay was paid by JFC, although his time slips were signed by G&B. Each day, Lindsay reported to G&B. David Eckert, G&B’s operations manager, directed Lindsay on where to go, what truck to drive, and his work hours. Lindsay received delivery paperwork from Eckert. Lindsay completed some odd jobs for G&B, including stacking boxes and running errands. G&B evaluated Lindsay’s work performance and had the ability to request a replacement if unsatisfied with his work. JFC had the exclusive ability to fire Lindsay. On March 18, 1988, Lindsay slipped while exiting a G&B truck and fell. As a result of complications of the injury, Lindsay’s leg was amputated. Lindsay filed for workers’-compensation benefits from JFC. At a hearing, the referee found that the amputation was causally related to Lindsay’s fall, and that JFC was responsible for paying benefits. The referee awarded total-disability benefits to Lindsay. JFC contested the award. The Workmen’s Compensation Appeal Board (the board) (plaintiff) affirmed the award of benefits but found G&B responsible for the payment of such benefits. JFC and G&B appealed to the commonwealth court. The commonwealth court found that there was substantial evidence to support the finding that Lindsay’s injury was causally related to the work accident. However, the commonwealth court reversed the board’s finding that G&B was the responsible party for the payment of benefits. The commonwealth court’s decision was appealed.

Rule of Law

Issue

Holding and Reasoning (Zappala, J.)

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