Ybarra v. John Bean Technologies Corp.

853 F. Supp. 2d 997 (2012)

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Ybarra v. John Bean Technologies Corp.

United States District Court for the Eastern District of California
853 F. Supp. 2d 997 (2012)

Facts

John Bean Technologies Corporation (JBT) (defendant) had a services agreement with labor broker Placement Pros, under which Placement Pros provided JBT with contingent staff for temporary work at JBT. The agreement provided that JBT was fully responsible for the safety of the work and the supervision and performance of all employees. Placement Pros assigned Pedro Ybarra (plaintiff) to a temporary job in JBT’s machine shop. JBT trained Ybarra, and Ybarra used both his own tools and JBT’s tools to perform the work. Ybarra was paid by the hour, and his work was part of JBT’s regular business. Ybarra was injured while working at JBT, and he sued JBT for negligence in federal district court. JBT argued that Ybarra’s negligence claim was precluded by California’s workers’-compensation statute, which provided that workers’-compensation benefits were an injured employee’s exclusive remedy. Ybarra asserted that the exclusive-remedy provision did not apply to him because he was an independent contractor and not a JBT employee. Ybarra claimed that he only spoke to JBT briefly each day regarding his assignments and otherwise performed his work without supervision. However, Ybarra had a work buddy at JBT who inspected and approved Ybarra’s work. JBT moved for summary judgment on Ybarra’s negligence claim.

Rule of Law

Issue

Holding and Reasoning (Snyder, J.)

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