Routine Maintenance v. Illinois Workers’ Compensation Comm’n

2022 IL App (1st) 211433WC‑U

1) Case citation and parties
- Routine Maintenance (appellant) v. Illinois Workers’ Compensation Commission; Richard Muniz (claimant/appellee). App. Ct. First District, Order filed Oct. 7, 2022. (Rule 23 order — non‑precedential.)

2) Key legal issues
- Whether an employer/employee relationship existed for purposes of the Illinois Workers’ Compensation Act, despite an “Independent Contractor” agreement, making Routine Maintenance liable for worker’s compensation benefits for injuries sustained while performing assigned work.

3) Holding/outcome
- The appellate court affirmed the circuit court’s confirmation of the Commission. The Commission’s finding that an employer/employee relationship existed was not against the manifest weight of the evidence; claimant is entitled to benefits.

4) Significant legal reasoning (concise)
- The court applied the familiar multifactor test focused on control and the totality of circumstances, not label or contract language alone. Critical factual findings supporting employer/employee status included: Routine Maintenance (through its office manager “Carlos”) hired/assigned the claimant; set the schedule and sequence of job tasks; supervised workers at the site; transported the crew in a company truck; procured/rented ladders for work beyond claimant’s own equipment; and arranged payment for jobs.
- Although an “Independent Contractor Agreement” was signed, the Commission reasonably concluded the contract’s label did not reflect the actual working relationship. The employer exercised sufficient control over the manner, means, and scheduling of work—key indicia of employment.
- The court emphasized deference to the Commission’s credibility and factual findings, reversing only if those findings were against the manifest weight of the evidence.

5) Practice implications (brief)
- Labels and boilerplate “independent contractor” agreements are insufficient if day‑to‑day practices show control: who hires/dispatches, who supplies vehicles/equipment, who sets schedules, whether supervision occurs, and how payment is handled.
- Employers should align written agreements with actual practice (e.g., contractors set their hours, supply tools, carry business insurance, receive 1099s, retain discretion over work methods) and maintain contemporaneous records demonstrating independence.
- For claimant counsel: emphasize concrete indicia of control (transport, supervision, equipment, direction). For defense counsel: secure witnesses and documents showing contractor autonomy and minimize evidence of employer control.
- Remember Rule 23 limitation: this decision is non‑precedential and binding only in limited contexts.