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Mansfield Enterprises, Inc. v. Warren

Citations: 270 S.E.2d 72; 154 Ga. App. 863; 1980 Ga. App. LEXIS 2421Docket: 59601

Court: Court of Appeals of Georgia; June 13, 1980; Georgia; State Appellate Court

Narrative Opinion Summary

In this case, Mansfield Enterprises, Inc. appealed a Superior Court order that reversed a State Board of Workers' Compensation decision which had denied benefits to the widow and minor children of an individual killed during a robbery while working at the company's store. The deceased had been working at the store for two days while applying for the position of store manager and had been performing various tasks. The Board initially found no implied contract for hire due to the absence of a 'meeting of the minds' between the deceased and the employer. However, the Superior Court overturned this decision, arguing that it was contrary to law and ordered a reconsideration of the evidence. The appellate court affirmed the Superior Court's verdict, underscoring that Board decisions, while generally conclusive, cannot rest on erroneous legal theories. The court cited precedent indicating that a master-servant relationship could be established without a formal contract if the employer benefits from the services performed. Consequently, the case was remanded to the Board for further findings based on correct legal principles, affirming the Superior Court's judgment with concurrences from Judges Deen and Birdsong.

Legal Issues Addressed

Review of Workers' Compensation Board Decisions

Application: The appellate court affirmed the Superior Court's decision, stating that Board decisions cannot be based on erroneous legal theories that prevent proper consideration of evidence.

Reasoning: The appellate court affirmed the Superior Court's decision, emphasizing that while the Board's awards are generally conclusive when supported by evidence, they cannot be based on erroneous legal theories that prevent proper consideration of evidence.

Workers' Compensation and Implied Contract for Hire

Application: The court determined that a master-servant relationship could exist under the Workers' Compensation Act even in the absence of a formal contract, if the employer benefits from the employee's services.

Reasoning: The court referenced a similar case, Howard Sheppard, Inc. v. McGowan, which established that a master-servant relationship can exist even without a formal contract if the employer benefits from the employee's services.