Beckner v. Maxim Crane Works, LP

Plaintiff filed a lawsuit against defendant alleging negligence under a theory of vicarious liability. The complaint alleged that plaintiff was injured when plaintiff’s employer, a home construction company, rented a crane from the defendant and that the defendant provided the equipment and the operator. The district court granted summary judgment in favor of the defendant, finding that plaintiff’s exclusive remedy was under the Indiana Workers’ Compensation Act because the crane operator was employed by plaintiff’s employer. The Seventh Circuit vacated and remanded, finding that the question of employment was fact-based and genuinely disputed and, as a result, summary judgment on that issue was not proper.