CRB Case Annotations re: Section 31-275(9)

Board affirmed trier’s finding that claimant was no longer an employee of the state during a post-retirement time period when he helped state’s attorney’s office with its preparation for a particular criminal trial. Testimony established that there was no agreement between the parties to pay the claimant for his services, nor was claimant under direction and control of state after his retirement date. See, Malchik, § 31-275(15), § 31-294c(a).

The trier interpreted the exclusion for workers who are “not regularly employed by the owner or occupier over twenty-six hours per week.” The trier interpreted “regularly” to mean the “tax season” during which the claimant (a home health care worker) was employed many more hours per week than the rest of the year. The board reviewed the purpose of the exclusion, and concluded that “regularly” refers to the average number of hours worked weekly during the 26 weeks preceding the injury. (Metro, C., dissenting): The dissenting commissioner interpreted “regularly” to mean 52, rather than 26, weeks preceding the injury.

Claimant was initially hired by respondent DHG, who subsequently entered into restructuring scheme whereby certain employment liabilities would be assumed by Flex-Staff, a Texas company with lower costs of doing business. Contract took effect October 1, 1990, though trier found that during initial stage of “phasing-in” period, Flex-Staff merely acted as payroll service while DHG retained control over means and methods of decedent’s work. Decedent died in work-related automobile accident on November 27, 1990. Held: Collateral estoppel doctrine did not apply to determination of Texas Workers’ Compensation Commission that decedent was employed by Flex-Staff at time of injury. Decision was subsequently set aside by Texas Court as part of compromise settlement, in which all liability was expressly denied. Also, no “identity of issues” existed, because joint employment relationship was possible in this case; one could find that both Flex-Staff and DHG exercised significant control over decedent’s work activities. See, Owen, § 31-275(1), § 31-278.

The board affirmed the trial commissioner’s conclusion that the claimant was an employee of the respondent employer at the time of his injury. The respondents argued that the respondent employer did not have sufficient control or supervision over the claimant’s work. However, the trial commissioner found that the respondent employer controlled the claimant’s work by telling the claimant how to safely use his ladder, after having a meeting on the subject without the claimant present.

CRB affirmed trier’s determination that claimant was acting as an employee, rather than an independent contractor, when he was injured while working for the respondent employer. Employer argued on appeal that claimant had signed a contract indicating that he was a “subcontractor,” had purchased his own disability insurance, and that the employer did not withhold taxes from his pay. However, numerous other factors indicated that claimant was under the direction and control of employer.

CRB affirmed trier’s finding that claimant was acting as an independent contractor rather than an employee of the Connecticut Post. The board thus affirmed the trier’s conclusion that the concurrent wage benefits provided under § 31-310 did not apply to the claimant’s concurrent employment with the Post. See also, Stalker, § 31-310, § 31-279-3.

Trial commissioner concluded that claimant failed to sustain his burden of proof that he was an employee of respondent. Claimant contended that trier erred by inferring that he was the operator of respondent business. Based on all of the evidence, including testimony of a witness, it was not unreasonable to infer that claimant operated business at the time of accident. Even without this inference, the record amply supports the conclusion that the claimant was not under the direction or control of the respondent at the time of his accident, and thus he may have been an independent contractor but not an employee. Board noted that claimant failed to provide any documentary evidence, such as his alleged employment application, time sheets, or payroll records, to indicate that he was acting as an employee.

Board concluded that the findings fully supported the trial commissioner’s conclusion that the claimant was acting as an employee rather than an independent contractor. The claimant was hired by the employer (a real estate developer who would purchase dilapidated buildings and refurbish them) to do repair work on a house in Connecticut. The trier’s findings supported the conclusion that the employer had the right to direct and control the claimant in the performance of her work. The board briefly found no merit to the argument that the claimant was not covered under the Act because she was allegedly not a citizen of this state, as the claimant was hired to do work “primarily in this state” under § 31-275(9)(B)(iv). See also, Davis, § 31-301. Appeal procedure.

CRB concluded that the evidence in the record fully supported the trier’s conclusion that the claimant was acting as an independent contractor.

CRB affirmed the trier’s conclusion that the claimant was acting as an employee of the respondent when he was injured. Although the claimant owned his own siding business and chose not to be covered under his workers’ compensation policy, he was injured while working outside the scope of his business. Specifically, the claimant was assisting the respondent with the removal of a window and was under the direction and control of the respondent for that project. See also, Nadeau, § 31-292.

Merlin v. Labor Force of America, Inc., 3920 CRB-4-98-10 (December 22, 1999), aff’d, 62 Conn. App. 906 (2001)(per curiam), cert. denied, 256 Conn. 922 (2001).

CRB affirmed trial commissioner’s conclusion that the claimant was an employee of the carpenter whom he was assisting on the day of his accident, rather than the employee referral agency that placed him at that job. Trier based decision on who had actual control over the means and methods of the claimant’s work, and permissibly exercised his discretion in ignoring evidence that LFA had represented that it would act as the employer for the purpose of administering employee benefits.

CRB affirmed the trier’s decision that the claimant was an employee rather than an independent contractor. The findings and the record supported the trier’s determination that the respondent had the right to direct and control the claimant in his performance of his work. See also, Murray, § 31-294d, § 31-307.

CRB affirmed trier’s decision that claimant was an employee of moving company rather than contractor who had been hired by company to provide services on its behalf. Commissioner was not required to rely upon terms of contract between company and contractor, as other evidence supported finding that moving company controlled the means and methods of the claimant’s job duties on the date of injury. See also, Johnson, § 31-294d, § 31-298.

CRB affirmed trial commissioner’s finding that claimant was employee of uninsured asbestos removal company, and that he was injured in the course of his employment with them. Factual findings supported legal conclusion, and in turn were themselves supported by evidence in the record. Appellant had unsuccessfully attempted to argue that claimant was actually working for a demolition/land contracting company owned by the director of Connecticut Abatement. See also, Puchala, § 31-291.

CRB affirmed trial commissioner’s decision that claimant was an employee rather than an independent contractor where the trier found that the respondent directed and controlled the work activities of the claimant.

CRB affirmed trier’s conclusion that claimant, who performed framing and roofing work, was an independent contractor. Trial commissioner found that claimant accomplished his job without direction, that no taxes were withheld from his pay, that he came and went from job sites at will, and that he used his own tools.

CRB affirmed the trial commissioner’s conclusion that the claimant was an independent contractor. The findings of fact supported the conclusion that the employer did not have control over the means and methods of the claimant’s work. Moreover, the trier’s decision was also bolstered by the facts that the claimant held himself out as a fully insured home improvement contractor, and that no taxes were withheld from his pay.

Claimant was a Rhode Island resident who was injured in Rhode Island. Her employer’s office was located in Connecticut. The trial commissioner found that the place of her employment relation was in Connecticut, and that of the 29 days she worked, she was in Connecticut for at least part of 19 of those days, though she was not in this state for 50% or more of her total work hours. As a traveling inventory specialist, she worked throughout New England and New York. The trial commissioner dismissed her claim, ruling that such a result was compelled by the CRB decision in Giordano v. Morganti, Inc., 15 Conn. Workers’ Comp. Rev. Op. 21, 3023 CRB-7-95-3 (November 9, 1995). The CRB disagreed, holding that the phrase “at least fifty per cent of his employment time” in § 31-275(9)(B)(vi)(I) should be interpreted broadly to include cases where the claimant has worked in Connecticut for at least a part of 50% or more of the various days worked. Policy behind the statute and its relationship with general jurisdictional principles of the Act discussed.

CRB affirmed the trial commissioner’s conclusion that the claimant was self-employed as a sole proprietor when he was injured. Also, § 31-291 does not apply where claimant is not an employee and thus no employment relationship exists. See also, Covillion § 31-291.

See, Kogut, § 31-291.

Dowling v. Slotnik, 3062 CRB-4-95-5, 3277 CRB-4-96-2 (February 5, 1997), aff’d, rev’d and remanded in part, 244 Conn. 781 (1998)(with dissenting opinion).

Definition of “employee” does not exclude illegal aliens. Federal criminalization of illegal alien employment does not preclude state from awarding workers’ compensation, as Chapter 568 is not punitive and does not relate to Immigration Reform and Control Act policies. Claimant’s falsification of information in job application does not affect existence of employment relationship or compensability of injury. Supreme Court affirmed holding that illegal aliens are not barred from receiving workers’ compensation benefits. Court reversed the trial commissioner’s imposition of a $10,000.00 fine for failure to carry insurance, as evidence did not support the imposition of the maximum fine, and remanded for determination of a lesser fine. See also, Dowling, § 31-288, § 31-301. Appeal procedure, and § 31-307.

Trial commissioner found that claimant was an employee rather than an independent contractor. Corrections sought by respondent were primarily based on testimony of claimant and employer’s officers, and did not have to be granted by commissioner, as other inferences could properly be drawn from that testimony as well. No one factor is controlling in employment determination, including claimant’s reporting in tax return amounts realized from work with respondent as profits by personal contracting business. Right to control, not tax filing strategy, is ultimate legal issue.

Claimant was hit by felled tree while operating noisy woodchipper. Commissioner found injury compensable. Affirmed. Failure of respondent to withhold deductions from claimant’s pay, as well as claimant’s not seeking unemployment benefits during time prior to accident, were not necessarily material to employment status. Sufficient evidence existed to support determination of employee status, e.g. control over work environment by employer and ownership of tree removal equipment. Burden on employer to establish both prongs of affirmative defense of intoxication under § 31-284(a). Not done here.

Trial commissioner found that nurse/ecologist was not an employee of medical practitioner. Affirmed; requested corrections to findings reflecting that much of claimant’s practice required direct supervision by physician, etc., were based on testimony that at best ambiguously supported her assertions. Commissioner had discretion to interpret testimony differently, or ignore it altogether. Also, language of § 20-87a(a) defining nursing practice as being under a physician’s direction does not translate into a legal requirement that the claimant must be an employee rather than an independent contractor.

Hanson v. Transportation General, Inc., 16 Conn. Workers’ Comp. Rev. Op. 57, 3001 CRB-3-95-2 (October 18, 1996), aff’d, 45 Conn. App. 441 (1997), aff’d, 245 Conn. 613 (1998).

Commissioner found that decedent taxi driver was an independent contractor rather than an employee of Metro Taxi. Affirmed. Commissioner was not required to use “relative nature of the work” test instead of “control” test to determine if employment relationship existed. Neither the legislature nor the courts of Connecticut have strayed from the “right to control” test in these cases, and it was properly applied to the facts here. Employment status is a factual issue, and is subject to certain deference on review. Findings offered sufficient support for finding that decedent was an independent contractor.

Kramer v. Johnson, 16 Conn. Workers’ Comp. Rev. Op. 43, 2217 CRB-6-94-11 (October 16, 1996).

Trier failed to make any factual findings or conclusions as to whether the putative employer had control over the alleged employee’s work activities relating to a roofing project. Further, the finding lacks evidentiary support concerning payment for services and is unclear as to whether respondent and claimant had an employment agreement. Remanded.

Thornton v. Kabel, 15 Conn. Workers’ Comp. Rev. Op. 353, 3027 CRB-4-95-3 (June 26, 1996).

Trier found respondent directed claimant to perform certain activities related to the felling of trees. Claimant fell while descending from a tree, when the clip of his safety harness to the rope broke. Claimant sustained various injuries. Trier’s factual finding that claimant was an employee of the respondent affirmed on appeal. See also, Thornton, § 31-301. Appeal procedure.

Pepin v. Carvalho, 15 Conn. Workers’ Comp. Rev. Op. 350, 3012 CRB-1-95-3 (June 26, 1996), aff’d, 44 Conn. App. 931 (1997)(per curiam).

The CRB affirmed the trial commissioner’s conclusion that the claimant was an independent contractor rather than an employee. The trial commissioner found that the claimant and Carvalho agreed that the claimant would keep track of his hours; that Carvalho would pay the claimant upon completion in a cash lump sum; that Carvalho would not make any deductions or withholdings from the lump sum payment; that Carvalho left up to the claimant when to report to work; that Carvalho left up to the claimant to decide how many hours to work per day; and that Carvalho did not instruct the claimant in the manner he did the paint job.

Nelson v. Deb’s Inc., 15 Conn. Workers’ Comp. Rev. Op. 274, 2228 CRB-3-94-12 (June 20, 1996), aff’d, 45 Conn. App. 909 (1997)(per curiam), dismissed, 244 Conn. 349 (1998).

Trial commissioner ruled that escort-masseuse was not an employee of the escort service. CRB affirmed. Commissioner had authority as fact finder to determine existence of employment relationship; he also had authority under § 31-298 to admit a signed, undated document entitled “Agreement” into evidence. Corrections urged by claimant depended on credibility of conflicting testimony, and were not erroneously denied; evidence in record supported decision that claimant controlled results and methods of her work. (Tracy, C., dissenting) (terminology of agreements irrelevant; escort service had authority to control appearance, conduct, and clientele of escorts, etc.). See also, Nelson, § 31-298.

The trial commissioner found that the decedent was a sole proprietor at the time he suffered a fatal heart attack on May 20, 1992, and thus was not covered under the Workers’ Compensation Act. The trial commissioner further found that the claimant had not elected to be covered under the workers’ compensation system pursuant to § 31-275(10). See also, Marandino, § 31-301-9. See subsequent decision, Marandino v. Marandino’s, 3130 CRB-6-95-7 (March 20, 1997), in § 31-275(10) and § 31-294c notes.

Tavares v. Noel, 15 Conn. Workers’ Comp. Rev. Op. 172, 2010 CRB-7-94-3 (March 8, 1996).

CRB affirmed trial commissioner’s award of benefits for compensable injury sustained by an illegal alien. An employee who is an illegal alien is not barred from receiving workers’ compensation benefits.

Carrier v. Voisine, 15 Conn. Workers’ Comp. Rev. Op. 105, 2093 CRB-3-94-7 (January 11, 1996).

Trial commissioner found claimant generally acted as independent contractor, but absence of signed agreement left respondent in control of claimant’s work activities, thus making claimant an employee. Reversed; not enough evidence to support decision. Commissioner inappropriately focused on fact that subcontracting agreement had not been properly signed, instead of studying respondent’s actual right to control the means and method of claimant’s work.

See, Giordano, § 31-278. Jurisdiction/Disqualification.

Zawadski v. Zaleski, 14 Conn. Workers’ Comp. Rev. Op. 322, 1973 CRB-1-94-2 (September 15, 1995), aff’d, 43 Conn. App. 909 (1996)(per curiam).

CRB affirmed commissioner’s determination that claimant was an employee rather than an independent contractor. The employer was a general contractor who hired a laborer who brought the claimant to work at the job site at the request of the employer. The employer had the right to control the claimant’s work.

CRB affirmed commissioner’s conclusion that claimant was an independent contractor rather than an employee. The claimant’s alleged acceptance of additional job duties without additional pay is not a determinative factor.

Dupree v. Masters, 13 Conn. Workers’ Comp. Rev. Op. 316, 1791 CRB-7-93-7 (April 25, 1995), aff’d, 39 Conn. App. 929 (1995)(per curiam).

Commissioner found that employer did not withhold social security or federal income tax payments from claimant’s wages; tax forms showed that claimant paid his own taxes at self-employment rates. Work could have been performed either as employee or independent contractor. Commissioner’s ruling that claimant was not an employee supported by facts; affirmed.

Muniz v. Koteas, 13 Conn. Workers’ Comp. Rev. Op. 284, 1720 CRB-4-93-5 (April 21, 1995).

Despite language of rental agreement labeling claimant as independent contractor, commissioner was entitled to base his conclusion that taxi driver was employee of respondent on his findings regarding the actual operation of the business. Findings satisfied definition of employee in statute. See also, Muniz, § 31-298.

Sufficient evidence existed to find claimant was employee of respondent despite absence of tax withholding in wages. See also, Phelan, § 31-291, § 31-301. Factual findings, and § 31-355(b). See subsequent Phelan, § 31-310.

Calamari v. Durham-Middlefield Interlocal Advisory Board, 12 Conn. Workers’ Comp. Rev. Op. 397, 1577 CRB-8-92-11 (September 8, 1994).

CRB majority opinion supports trier’s finding claimant, who performed gate guard services for respondent employer, received no control or direction as to the means and method of his work and was therefore an independent contractor. (Waldron, C., dissenting) Evidence indicates employer had sufficient control over how claimant performed his work to establish an employer-employee relationship.

DaSilva v. Danbury Publishing Co., 12 Conn. Workers’ Comp. Rev. Op. 360, 1647 CRB-7-93-2 (August 2, 1994), aff’d, 39 Conn. App. 653 (1995), cert. denied, 235 Conn. 936 (1995).

Newspaper carrier not an employee under the Act. (Miles, C., dissenting).

Pichardo v. East-West Theatre Productions, 12 Conn. Workers’ Comp. Rev. Op. 186, 1553 CRB-3-92-11 (May 2, 1994).

Finding that claimant, an aspiring actor, was not an employee but an independent contractor who engaged in a joint venture to perform in a theatrical performance supported by evidence.

Halliday v. Daw’s Critical Care Registry, Inc., 10 Conn. Workers’ Comp. Rev. Op. 187, 1196 CRD-7-91-3 (September 14, 1992), dismissed for lack of final judgment, A.C. 11770, cert. denied, 225 Conn. 905 (1993).

Trier’s finding claimant an employee of Darien Convalescent Center supported by evidence. Remanded on § 31-297(b) (now § 31-294c) issue. See also, Halliday, § 31-294c.

Chute v. Mobil Shipping and Transportation, 10 Conn. Workers’ Comp. Rev. Op. 183, 1321 CRD-7-91-10 (September 1, 1992), aff’d, 32 Conn. App. 16 (1993), cert. denied, 227 Conn. 919 (1993).

CRB affirmed trier’s ruling denying claimant widow’s Motion to Preclude. Trier found no employer/employee relationship existed between decedent and respondent employer. Employer’s right to discharge decedent is not the equivalent of the employer’s right to control. The employer’s right to discharge and the tasks performed by decedent, are not the only factors to be considered in determining the requisite control necessary to establish the existence of an employer/employee relationship. See also, Chute, § 31-294c and § 31-301. Appeal procedure.

Russell v. R.N. Russell Welding, Inc., 10 Conn. Workers’ Comp. Rev. Op. 174, 1173 CRD-5-91-2 (September 1, 1992), aff’d, 226 Conn. 508 (1993).

CRB affirmed trier’s finding that decedent, President and Treasurer of R.N. Russell Welding, Inc. agent for service of process as well as sole shareholder, elected to be excluded from coverage. The mere fact that decedent did not serve the exclusion form upon himself pursuant to § 31-275(6)(D) (now § 31-275(10)(D)) does not make notice ineffective. Hence, fatal injury found not compensable under the workers’ compensation act.

Reale v. Carducci, 10 Conn. Workers’ Comp. Rev. Op. 158, 1205 CRD-5-91-3 (June 30, 1992).

CRB’s review of issues on appeal after remand does not change resulting disposition. Factual finding supports trier’s conclusion claimant was an employee at the time of his injury.

Keefe v. Flynn, 10 Conn. Workers’ Comp. Rev. Op. 98, 1169 CRD-2-91-1 (April 23, 1992).

Trier’s finding claimant, a truck driver, was an employee of respondent-employer will not be disturbed where findings and conclusions are supported by evidentiary record. The evidence showed the respondent directed the route of each trip, and paid gas, insurance and licensing fees.

Hynd v. General Electric Company, 10 Conn. Workers’ Comp. Rev. Op. 77, 1151 CRD-4-90-12 (April 3, 1992).

Remanded so that further factual findings may be made on the issue of the putative employer’s control over the claimant’s work activities. No findings to support legal conclusion claimant, a proofreader for respondent employer, was an independent contractor. The fact that claimant was a professional in and of itself does not make her an independent contractor.

Zawadzki v. Kochanowicz, 10 Conn. Workers’ Comp. Rev. Op. 62, 1120 CRD-5-90-10 (February 26, 1992).

CRB review of record below indicates trial commissioner relied on the credibility of the witnesses in finding claimant was an employee and not an independent contractor. Also, as evidence could suggest an employer/employee relationship and trier found such existed, CRB cannot say trier’s conclusion arose from an unreasonable factual inference or that his conclusion was so unreasonable as to justify appellate interference. See also, Zawadzki, § 31-301. Factual findings.

Hart v. National Academy of Hairdressing, 10 Conn. Workers’ Comp. Rev. Op. 10, 945 CRD-6-89-11 (April 15, 1991).

Trier’s determination claimant was not an employee will not be disturbed on appeal where factual finding is supported by evidence.

Reale v. Carducci, 9 Conn. Workers’ Comp. Rev. Op. 31, 901 CRD-1-89-8 (January 17, 1991).

Remanded as trial commissioner failed to make specific findings to support conclusion claimant was an employee. See also, Reale, supra.

Clark v. Armando Massini, 9 Conn. Workers’ Comp. Rev. Op. 14, 857 CRD-2-89-4 (January 9, 1991).

Trier’s factual finding claimant was employee of Massini and not TRA Contractors, Inc., a solely owned corporation of Massini, will not be disturbed.

Milliron v. Armando Massini, 9 Conn. Workers’ Comp. Rev. Op. 14, 858 CRD-2-89-4 (January 9, 1991).

Vanzant v. Hall, 8 Conn. Workers’ Comp. Rev. Op. 122, 820 CRD-1-89-1 (July 6, 1990), rev’d, 219 Conn. 674 (1991).

Sufficient evidence before the trial commissioner to conclude respondent had the requisite control over the claimant necessary to establish an employment relationship. § 31-275(5)(B) (casual employee). Whether claimant’s employment by respondent was (1) casual and (2) not for employer’s trade or business is a factual question. Further both requirements under the statute must be satisfied. § 31-275(5)(D). Construction of a barn is not the type of service in or about a private dwelling contemplated by the statute. Supreme Court reversed CRB and held claimant was not an employee within the meaning of the act.

Rogers v. Mitchell, 8 Conn. Workers’ Comp. Rev. Op. 90, 803 CRD-7-88-12 (May 14, 1990).

Trial commissioner’s finding claimant was an independent contractor will not be disturbed where it was found respondent did not have the right to control the means and methods of work performed. See also, Rogers, § 31-301-9. Additional evidence.

Halliday v. Daw’s Critical Care Registry, 8 Conn. Workers’ Comp. Rev. Op. 74, 797 CRD-7-88-12 (April 27, 1990).

See, Halliday, § 31-291. Later decision in Halliday, 1196 CRD-7-91-3 (September 14, 1992), supra.

Pisani v. Messore, 8 Conn. Workers’ Comp. Rev. Op. 11, 753 CRD-3-88-7 (December 28, 1989), aff’d, 23 Conn. App. 806 (1990)(per curiam).

Whether a claimant is an employee or an independent contractor is a question of fact.

Superior court judge not an employee under the Act. See, Kinney, § 31-324.

Velez v. Richard Zappone, 7 Conn. Workers’ Comp. Rev. Op. 79, 693 CRD-5-88-2 (September 14, 1989), no error, 21 Conn. App. 812 (1990)(per curiam).

Casual employee. Employment was occasional or incidental and not for the purpose of respondent’s trade or business. No employment relationship to support jurisdiction over the res. See also, Castro v. Viera, 207 Conn. 420 (1988).

Lindholm v. Moscowitz, 6 Conn. Workers’ Comp. Rev. Op. 7, 527 CRD-7-86 (August 18, 1988).

CRD affirmed trial commissioner’s finding as to casual employee status.

Bernier v. Cunningham Reporting Associates, 5 Conn. Workers’ Comp. Rev. Op. 137, 502 CRD-1-86 (July 15, 1988).

Trial commissioner’s finding that claimant was an employee was supported by evidence. Failure to withhold social security or unemployment taxes does not preclude finding of employment.

Tyson v. Southport Manor, 5 Conn. Workers’ Comp. Rev. Op. 84, 475 CRD-4-86 (May 12, 1988).

Employee listed with a Nurses’ Registry as a Home Health Aide but employed by a patient in a convalescent home is not an employee of the convalescent home.

Ukers v. Brook, 5 Conn. Workers’ Comp. Rev. Op. 51, 372 CRD-7-85 (April 7, 1988).

Trial commissioner’s ruling that claimant was an employee of respondents as individuals would not be disturbed as payment to claimant from corporate funds is only a factor to be considered in determining employment status.

Chillington v. Spenard’s Roofing, 4 Conn. Workers’ Comp. Rev. Op. 102, 389 CRD-7-85 (June 15, 1987).

Where claimant filed a tax return in which he stated he was engaged in business under the name of Twin Ridge Roofing, accepted checks from general contractor made out to same, and had a general liability policy of the business, evidence supported conclusion he was a subcontractor.

Barnett v. Stafford, 4 Conn. Workers’ Comp. Rev. Op. 7, 219 CRD-1-83 (March 2, 1987).

Assistant dog warden held public official.

Gadacy v. Busk, 4 Conn. Workers’ Comp. Rev. Op. 1, 431 CRD-4-85 (February 26, 1987).

Claimant who performed tasks of a carpenter among other tasks found to be an employee.

CRB Case Annotations re: Section 31-275(9)

Employee.