Utah Supreme Court
Does Utah's workers' compensation act still use the fellow-servant doctrine? Stamper v. Johnson Explained
Summary
Sharon Stamper died in a vehicle accident while riding as a passenger with Rebecca Johnson, both employees of companies owned by Steve Gilbert. The district court granted summary judgment for Johnson based on the fellow-servant doctrine, but the Utah Supreme Court reversed, holding that the 1975 amendments to the Workers’ Compensation Act eliminated the fellow-servant doctrine.
Analysis
Background and Facts
Sharon Stamper and Rebecca Johnson worked for separate companies owned by Steve Gilbert. Stamper was employed by Gilbert Development Corporation, while Johnson worked for Diamond G Rodeos. On May 6, 2005, Cyndi Gilbert asked both women to travel from Toquerville to Mesquite to move the Gilberts’ home office. Johnson drove a Gilbert Development vehicle with Stamper as a passenger. Johnson lost control of the vehicle, which rolled over, killing Stamper. Stamper’s family received workers’ compensation benefits and subsequently sued Johnson for negligent driving.
Key Legal Issues
The central issue was whether the Workers’ Compensation Act’s exclusive remedy provision barred the wrongful death claim against Johnson. The district court relied on the fellow-servant doctrine from Peterson v. Fowler (1972), which applied to the pre-1975 Act’s “same employment” language. The question became whether this doctrine remained applicable after the 1975 statutory amendments.
Court’s Analysis and Holding
The Utah Supreme Court held that the district court erred by applying the fellow-servant doctrine. The court explained that the 1975 amendments to the Workers’ Compensation Act removed the “same employment” language that had incorporated the common law fellow-servant doctrine. The current Act’s exclusive remedy provision now bars claims only against “an employer, officer, agent, or employee of the employer.” The court emphasized that statutory interpretation must focus on the current plain language rather than outdated doctrines. The case was remanded to determine whether Johnson was an agent or employee of Gilbert Development under modern agency and employment relationship standards.
Practice Implications
This decision fundamentally changed Workers’ Compensation Act analysis in Utah. Practitioners must abandon fellow-servant doctrine arguments and instead focus on whether defendants qualify as officers, agents, or employees of the injured party’s employer. The ruling requires careful factual development regarding agency relationships and employment status, particularly in cases involving related corporate entities with common ownership or control.
Case Details
Case Name
Stamper v. Johnson
Citation
2010 UT 26
Court
Utah Supreme Court
Case Number
No. 20090062
Date Decided
April 30, 2010
Outcome
Reversed
Holding
The 1975 amendments to the Workers’ Compensation Act eliminated the fellow-servant doctrine by removing the ‘same employment’ language, requiring instead a determination of whether the defendant was an officer, agent, or employee of the plaintiff’s employer.
Standard of Review
Correctness for questions of law; summary judgment reviewed for correctness with no deference to trial court’s conclusions of law
Practice Tip
When analyzing Workers’ Compensation Act exclusivity, focus on whether the defendant was an officer, agent, or employee of the plaintiff’s employer rather than applying the outdated fellow-servant doctrine.
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