Melquiades Flores, Sr., and Mary Flores, Individually and as Representative of the Estate of Their Son, Melquiades Flores, Jr. v. North America Technologies Group, Inc., Tietek, Inc And Skillmaster, Inc.
Melquiades Flores, Sr. and Mary Flores (the Floreses) appealed a summary judgment rendered in favor of TieTek, Inc. (and its parent company North American Technologies Group, Inc.) and Skillmaster Staffing Services, Inc. The Floreses filed a wrongful death action after their son, Mike Flores, sustained fatal injuries while working at TieTek's facility, having been assigned there by Skillmaster, a temporary employment agency. The central issue on appeal was whether TieTek qualified as Mike Flores's employer, which would entitle TieTek to the exclusive remedy provision of the Texas Workers' Compensation Act (TWCA). The trial court granted summary judgment for both defendants. The appellate court affirmed the trial court's judgment, holding that the right-to-control test is still applicable for determining employer status under the TWCA and that TieTek exercised sufficient control over Mike Flores's work details to be considered a borrowed servant employer, thus qualifying for the exclusive remedy provision.