Hartford Underwriters Insurance Co. v. Dale Penney, d/b/a DLP Construction Co.
Hartford Underwriters Insurance Co. sued Dale Penney, d/b/a DLP Construction Co., to recover additional workers' compensation insurance premiums. The dispute centered on whether workers utilized by Penney were employees or independent contractors for premium assessment purposes, particularly in light of I-18 "Election of Non-Coverage by Subcontractor" Forms. The trial court ruled in favor of Hartford, finding the workers to be employees and awarding $12,316 plus costs and pre-judgment interest. On appeal, the Court of Appeals of Tennessee affirmed the trial court's finding that the workers were employees, thus upholding the premium assessment, but vacated the award of pre-judgment interest and remanded that issue for further clarification from the trial court.