The North Carolina Supreme Court issued an opinion Dec. 12, 2025, in *Lassiter v. Robeson County Sheriff's Department* that clarifies when multiple employers can be held jointly liable in workers' compensation cases involving public agencies and private contractors.
The court held that plaintiff Steven Matthew Lassiter does not satisfy the control requirement for joint employment with Truesdell Corporation, reversing the Court of Appeals decision that had recognized the private company as a joint employer alongside the Robeson County Sheriff's Office.
The case stems from a workers' compensation dispute involving multiple alleged employers and their insurance carriers. Lassiter worked as a law enforcement officer for the Robeson County Sheriff's Office beginning in March 2008. Under the sheriff's office written policy, employees could earn additional income through approved off-duty employment opportunities, but were required to obtain prior approval from the Sheriff or his designee before accepting such assignments.
The litigation involved four parties claiming employer or carrier status: the Robeson County Sheriff's Department with alleged carrier Synergy Coverage Solutions, and Truesdell Corporation with alleged carrier The Phoenix Insurance Company. The case proceeded through the North Carolina Industrial Commission, which issued an opinion and award on Nov. 17, 2022.
The Court of Appeals reviewed the Industrial Commission's decision in 2023, issuing a unanimous ruling reported at 291 N.C. App. 579 that affirmed in part and reversed in part the commission's findings. The appeals court determined that Truesdell Corporation qualified as a joint employer, a finding that the Supreme Court has now rejected.
The Supreme Court accepted discretionary review under N.C.G.S. § 7A-31 and heard oral arguments on April 17, 2025. Justice Barringer authored the opinion for the court, which focused on clarifying North Carolina's joint employment doctrine and applying it to the specific factual circumstances presented.
The joint employment doctrine is crucial in workers' compensation law because it determines which entities bear liability for workplace injuries and which insurance carriers must provide coverage. When multiple employers exercise sufficient control over a worker, they can be held jointly liable for compensation benefits.
The Supreme Court's analysis centered on the "control requirement" for joint employment. Under this legal standard, an entity must exercise sufficient control over the employee's work activities to qualify as an employer for workers' compensation purposes. The court found that Truesdell Corporation did not meet this threshold despite its contractual relationship with the sheriff's office.
The decision represents a significant clarification of North Carolina employment law, particularly for cases involving public safety officers who work additional assignments for private companies. Many law enforcement officers supplement their income through off-duty security work, private investigations, or special event assignments arranged through their departments.
Lassiter was represented by Stephen C. McIntyre of McIntyre Law Office, PLLC. Truesdell Corporation and The Phoenix Insurance Company were represented by M. Duane Jones and Neil P. Andrews of Hedrick Gardner Kincheloe & Garofalo LLP. The Robeson County Sheriff's Department and Synergy Coverage Solutions were represented by Allegra A. Sinclair and Gregory S. Horner of Goldberg Segalla LLP.
The American Property Casualty Insurance Association participated as amicus curiae, represented by Frances M. Clement of Wilson Ratledge, PLLC, highlighting the broader industry implications of the joint employment determination.
The ruling provides important guidance for employers, insurance carriers, and workers' compensation attorneys in North Carolina. By clarifying the control requirement for joint employment, the court has established clearer parameters for determining liability in cases involving multiple potential employers.
For public agencies that allow off-duty work arrangements, the decision offers greater certainty about when private contractors might be considered joint employers. The ruling suggests that contractual relationships alone may not be sufficient to establish joint employment without evidence of actual control over the employee's work activities.
The decision also has implications for insurance coverage determinations. When joint employment is established, multiple carriers may share liability for workers' compensation benefits. The Supreme Court's clarification of the control requirement will help carriers and employers better assess their potential exposure in multi-employer situations.
The case reflects the evolving nature of employment relationships in the modern economy, where workers increasingly have multiple income sources and employers often rely on complex contractor arrangements. The Supreme Court's guidance on joint employment will help resolve disputes arising from these layered employment relationships.
Going forward, the *Lassiter* decision will serve as controlling precedent for North Carolina courts evaluating joint employment claims in workers' compensation cases. The clarified doctrine should reduce uncertainty and litigation costs by providing clearer standards for determining when multiple entities can be held jointly liable for workplace injuries.