This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A truck driver employed by Sierra Transportation, Ltd. sought workers' compensation benefits after being injured in an accident while hauling products for Rocky Mountain Metals, Inc. The driver argued that he was an employee of Rocky Mountain Metals or that the company was liable under an alter ego theory. Rocky Mountain Metals and Sierra Transportation were separate entities, with distinct operations, finances, and ownership structures (paras 2-7).
Procedural History
- Workers' Compensation Administration: The workers' compensation judge (WCJ) found that the driver was an employee of Sierra Transportation, not Rocky Mountain Metals, and dismissed the claim for benefits against Rocky Mountain Metals (paras 7, 11).
Parties' Submissions
- Appellant (Worker): Argued that he was an employee of Rocky Mountain Metals based on interlocking ownership, shared resources, and control over his work. Alternatively, he claimed that Rocky Mountain Metals was liable under an alter ego theory (paras 1, 9-10).
- Appellees (Rocky Mountain Metals and Insurer): Contended that the worker was employed solely by Sierra Transportation, which was a separate legal entity, and that Rocky Mountain Metals had no control over the worker's employment or liability for his injuries (paras 7, 11-12).
Legal Issues
- Was the worker an employee of Rocky Mountain Metals, Inc. and therefore entitled to workers' compensation benefits?
- Could Rocky Mountain Metals, Inc. be held liable under an alter ego theory for the worker's injuries?
Disposition
- The Court of Appeals of New Mexico affirmed the decision of the workers' compensation judge, holding that the worker was not an employee of Rocky Mountain Metals and that the alter ego theory was not applicable (paras 1, 13-14).
Reasons
Per Sutin J. (Alarid and Fry JJ. concurring):
The court found substantial evidence supporting the WCJ's conclusion that the worker was employed by Sierra Transportation, not Rocky Mountain Metals. The two entities were legally and operationally distinct, with separate finances, ownership, and management. The worker was paid by Sierra Transportation, which owned the trucks and bore all associated costs. Rocky Mountain Metals merely contracted Sierra Transportation for hauling services and did not exercise control over the worker's employment (paras 7, 11-12).
The court rejected the worker's alter ego argument, noting that it was not properly preserved at the WCJ level and that the evidence presented was insufficient to establish the necessary factors for alter ego liability under New Mexico law (para 13).