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Gerard v. Scott Crane Rental Corp.

Citations: 754 So. 2d 896; 2000 WL 460361Docket: 1D99-706

Court: District Court of Appeal of Florida; April 25, 2000; Florida; State Appellate Court

Narrative Opinion Summary

An accident on January 14, 1997, resulted in Appellant Paul Vincent Gerard being shocked and injured by a crane operated by an employee of Appellee Scott Crane Rental Corp., which had leased the crane to Appellant's employer for one day. Appellee sought summary judgment claiming its employee was a "borrowed servant" of Appellant's employer, thus immune from tort claims due to workers' compensation immunity under Florida Statute 440.11. The court emphasized that summary judgment requires conclusive evidence that no genuine issues of material fact exist, with all inferences favoring the opposing party. Upon reviewing the case, the court identified genuine issues of material fact regarding the borrowed servant status of Appellee's employee, leading to the reversal of the summary judgment and remanding the case to the trial court for further proceedings. Judges Booth, Lawrence, and Davis concurred with the decision.

Legal Issues Addressed

Borrowed Servant Doctrine in Workers' Compensation

Application: The court examined whether the employee of Scott Crane Rental Corp. was a 'borrowed servant' of Appellant's employer, which would grant immunity from tort claims under Florida Statute 440.11.

Reasoning: Appellee sought summary judgment claiming its employee was a 'borrowed servant' of Appellant's employer, thus immune from tort claims due to workers' compensation immunity under Florida Statute 440.11.

Reversal of Summary Judgment

Application: The court reversed the summary judgment due to the existence of genuine issues of material fact concerning the borrowed servant status, necessitating further proceedings in the trial court.

Reasoning: Upon reviewing the case, the court identified genuine issues of material fact regarding the borrowed servant status of Appellee's employee, leading to the reversal of the summary judgment and remanding the case to the trial court for further proceedings.

Summary Judgment Standards

Application: Summary judgment is appropriate only when there is conclusive evidence that no genuine issues of material fact exist, and all inferences must favor the opposing party.

Reasoning: The court emphasized that summary judgment requires conclusive evidence that no genuine issues of material fact exist, with all inferences favoring the opposing party.