Transportation Executive Summary: Court of Appeals Affirms Decision Denying Second Suit - Driver Subject to Joint Employer Rule


Recently, the United States Court of Appeals for the Eighth Circuit ruled on a workers’ compensation issue. Quiles v. Johnson, 906 F.3d 735 (8th Cir. 2018). The case was unusual in the sense the federal appellate courts tend not deal with such issues. But this case is of note to the transportation industry. Specifically, the Court was faced with the question of whether an employee who was injured in an accident caused by his “driving mentor” during the course of employment was limited to workers’ compensation benefits as his exclusive remedy under the Iowa workers’ compensation statute. Ultimately, the Court affirmed the district court’s grant of summary judgment in favor of the defendant, finding that workers’ compensation benefits were plaintiff’s exclusive remedy under the Iowa workers’ compensation statute and dismissed the case against the mentor.

Litigation arose after plaintiff, a new employee of an interstate motor carrier was injured by his “driving mentor” while completing the company’s commercial driving training program. The “driving mentor” fell asleep at the wheel and drove the tractor-trailer off I-80 in Adair County, Iowa, causing plaintiff to sustain severe injuries.

On September 5, 2017, the district court granted the defendant driver’s motion for summary judgment. The judgment was appealed and the matter was taken up by the United States Court of Appeals for the Eighth Circuit. Ultimately, the Eight Circuit affirmed the decision of the district court, upholding the decision to grant summary judgment. In doing so, the Court of Appeals for the Eighth Circuit held that the plaintiff and defendant entered into an employment relationship in which the defendant driver and the interstate motor carrier were joint employers mutually liable under Iowa law to provide the plaintiff workers’ compensation benefits should a work-related injury occur. As such, the workers’ compensation benefits are the plaintiff’s exclusive remedy against the defendant.

Contact John F. Fatino for more information about trucking and transportation matters at 515-288-6041. Bryn E. Hedlund, J.D. Candidate, University of Iowa Law School assisted in the preparation of these materials.


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