Angelotti

Anthony Angelotti was injured while rehearsing a stunt for a film. He filed a complaint against several parties associated with the film production. The trial court concluded that a production company, Second Mate Productions, Inc. (Second Mate), was Angelotti’s special employer and that the workers’ compensation exclusivity rule precluded any recovery against either Second Mate or its employee, Jim Stephan. The court also concluded that The Walt Disney Company (Disney Company) and other defendants owed Angelotti no duty of care. The court granted summary judgment in favor of the defendants.

Angelotti contends whether he was a special employee of Second Mate is a question of fact that cannot be resolved on summary judgment. He also contends Disney Company and other defendants assumed a duty to ensure that the production complied with occupational safety regulations, and those defendants retained control over the film production and affirmatively contributed to his injury by providing unsafe equipment and failing to ensure his safety.

We conclude that the evidence compels the conclusion that Angelotti was an employee of Second Mate and that the workers’ compensation…