Carrion v. Orbit Messenger, Inc.
This dissent addresses whether a truck driver, Frank Henry, is an employee of Orbit Messenger, Inc. or an independent contractor, which impacts Orbit's liability under respondeat superior. The dissenting judge argues against a rule that mandates a factual determination in every such case, which could burden small businesses. Based on the record, the judge agrees with the motion court's finding that Henry is an independent contractor. Key factors include Henry's ownership and maintenance of his truck, control over routing and timing, payment structure (57% of billings, 1099 form), and lack of payroll deductions or benefits. The dissent concludes there is no showing that Orbit reserved control over Henry, advocating for dismissal as to Orbit, citing Shapiro v Robinson as a guiding precedent.