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Can I Have Multiple Employers for Purposes of Workers’ Compensation?


Workers’ compensation is considered the “exclusive remedy” under Iowa law for employees to seek compensation from their employers for a work-related injury. In other words, you cannot file a personal injury lawsuit against your company if you are already receiving workers’ compensation benefits. The law is designed to guarantee employees receive medical and wage replacement benefits without the need for extensive litigation.

Federal Court Holds Truck Driver “Mentor” Cannot Be Sued by Injured Apprentice

As a general rule, the exclusive remedy of workers’ compensation only applies to your employer and not to any third parties. Let’s say you were driving a company-owned vehicle on a work-related matter. Another driver runs a red light and slams into you. You could still sue the negligent driver for damages, as workers’ compensation only protects your employer.

But there are other scenarios where a third party may be classified as a “joint employer” for workers’ compensation purposes. The U.S. Eighth Circuit Court of Appeals, which oversees appeals from Iowa’s federal courts, recently addressed such a case. In Quiles v. Johnson, the plaintiff (Quiles) was an apprentice commercial truck driver for Swift Transportation, an Arizona-based company. As part of his training, the plaintiff was assigned to a “mentor”–the defendant (Johnson), who was an experienced truck driver working as an independent contractor for Swift.

While driving on I-80 through Iowa, the defendant “fell asleep at the wheel” and drove his tractor-trailer off the road, according to court records. The plaintiff was “off-duty in the truck’s sleeper berth” at the time. The plaintiff subsequently received workers’ compensation benefits from Swift. He then filed a separate personal injury lawsuit against the defendant.

Unfortunately, both the trial court and the Eighth Circuit held that Iowa law barred the plaintiff’s personal injury claim, as the defendant was also legally the plaintiff’s “employer” for workers’ compensation purposes. The appeals court explained it is possible for an employee “to have more than one employer” for workers’ compensation purposes. And although Iowa law presumes there is only one employer, that presumption can be overcome if there is sufficient evidence of a “joint” employment situation.

Here, the plaintiff “performed closely related services for both Swift and [the defendant].” And the defendant actually made contributions to Swift to defray the costs of purchasing workers’ compensation insurance to cover the plaintiff. Furthermore, through his own actions the plaintiff clearly established the existence of an apprenticeship relationship with the defendant–and Iowa workers’ compensation law expressly recognizes apprenticeships as a “contract of service” performed “for an employer.”

Speak with a Fairfield, Iowa Workers’ Compensation Lawyer Today

Workers’ compensation often serves to protect the interests of employers at the expense of injured workers. This is why it is important to work with an experienced Southeast Iowa workers’ compensation lawyer if you are faced with a claim that potentially involves multiple employers. Contact the Noyes Law Office, P.C., at 641-472-3236 to schedule a free, no-obligation consultation with a member of our legal team today.


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