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Johnson v. R.R. Donnelley & Sons Co.

Citations: 185 Ill. App. 3d 759; 542 N.E.2d 379; 134 Ill. Dec. 200; 1989 Ill. App. LEXIS 943Docket: Nos. 1-86-2911, 1-86-3022, 1-86-2998 cons.

Court: Appellate Court of Illinois; June 23, 1989; Illinois; State Appellate Court

Narrative Opinion Summary

This case involves a workplace injury sustained by the plaintiff, Johnson, while working on a scaffold at a plant, leading to his lawsuit against multiple parties. Johnson sued for violations of the Illinois Structural Work Act and filed a strict products liability claim against Crown Corr Erection, Inc. for supplying a defective scaffold. Crown Erection, in turn, sought contribution from R.J.R. Inc., who provided labor for the installation. The trial court granted a directed verdict in favor of R.J.R., dismissing Crown's contribution claim, which became the focal point of the appeal. The appellate court reversed this decision, highlighting unresolved factual disputes regarding the agency status of Mel Lolkema, an employee involved in the hiring and management of the work crew. The appellate court emphasized that the trial court erred by not allowing the jury to resolve these factual ambiguities, particularly the roles and actions of R.J.R. employees concerning scaffold safety. Consequently, the case was remanded for a new trial on the issue of contribution, allowing for further examination of potential shared liability among the parties involved.

Legal Issues Addressed

Agency in Employment Context

Application: The trial court's decision was challenged based on the agency status of Mel Lolkema, with evidence suggesting he acted as an agent for both Crown and R.J.R.

Reasoning: The key contention during the trial was whether Mel Lolkema, an R.J.R. employee who hired Johnson, was acting as R.J.R.'s agent or as Crown Erection's agent.

Contribution Among Tortfeasors

Application: Crown Erection's third-party complaint sought contribution from R.J.R. based on shared fault, which was mishandled by the trial court's directed verdict.

Reasoning: Crown Erection subsequently filed a third-party complaint against R.J.R. for contribution based on its share of fault in Johnson’s injuries.

Directed Verdict Standards

Application: The court reversed the trial court's directed verdict in favor of R.J.R., holding that factual disputes regarding agency status precluded such a ruling.

Reasoning: A verdict should only be directed when the evidence, viewed favorably for the opposing party, overwhelmingly supports the movant to the extent that no contrary verdict could stand.

Illinois Structural Work Act

Application: Johnson's claim involved alleged violations under the Illinois Structural Work Act, focusing on the scaffold's condition and the actions of R.J.R. employees.

Reasoning: Johnson filed a complaint against Donnelley and Mid-American Engineers, Inc., claiming violations of the Illinois Structural Work Act...

Strict Products Liability

Application: The case included a strict products liability claim against Crown Erection for the defective scaffold used during the installation.

Reasoning: ...and a strict products liability action against Crown Erection for a defective scaffold.