Green, Crystal v. 101 Vape & Smoke, LLC
Crystal Green, an employee, appealed a trial court's decision regarding her workers' compensation claim against 101 Vape & Smoke, LLC, following a right ankle injury. The trial court had initially ruled that multiple related companies with common ownership could be considered a single entity, thus meeting the five-employee threshold for workers' compensation coverage, and ordered the employer to provide a panel of physicians. However, it denied temporary disability benefits due to a lack of medical evidence. The Appeals Board reversed this decision, finding insufficient proof that 101 Vape & Smoke, LLC, as a standalone entity, employed the requisite number of people. The Board emphasized that the critical inquiry is whether the specific employer directly utilized the services of five or more paid individuals, not whether separate LLCs could be collectively grouped without such evidence, and remanded the case for further proceedings.