Brooks v. Central Sainte Jeanne

Background

A worker was sent by his employer’s buyer in Puerto Rico to help set up a boiler for the company. He rode in the company automobile to fetch the boiler, driven by another employee. On the return trip the car was negligently driven into a ditch and the worker was badly hurt. At trial, after the worker presented his evidence, the judge ordered a verdict for the company and the worker objected.

Reasoning

The main question was whether the injured man was acting as the company’s servant and therefore a fellow worker of the driver. The Court explained that the trip was undertaken as part of the company’s work, the worker was under the company’s orders during the trip, and so he was the company’s servant and a fellow servant of the driver. The opinion noted that Puerto Rico’s 1902 statute copied the English Employers’ Liability Act and presupposes the common-law fellow-servant rule. The Court also rejected a late claim that the employer had hired an incompetent, drunken driver, finding the evidence too weak to let a jury decide that point. The judgment for the company was affirmed.

Real world impact

The ruling limits situations where a worker can hold an employer liable for a co-worker’s negligence during company tasks or errands. It highlights that trips made for work bring the worker under the employer’s orders. Weak or speculative evidence about a co-worker’s drinking is not enough to prove employer responsibility.