A "livestock load brokerage service" has been declared the "category one statutory employer" of a truck driver who was headbutted and trampled by a cow while loading the animal into a truck. The case is Eldridge v. Agar Livestock, 2022 Ida. LEXIS 115 (Idaho 2022).
Meissen Trucking (Meissen) entered a series of intricate brokerage and lease agreements with Agar Livestock, LLC (Agar) where Agar would "procure contracts for the transportation of livestock" and pass them on to Meissen. Though the brokerage agreement specified that Agar did not employ Meissen and that Meissen was an independent contractor, it also stated throughout the agreement that Meissen "transport[ed] livestock for Agar."
In January 2018, Agar was asked to help transport a load of cattle from a feedlot in Idaho to a facility in Washington state. Jason Eldridge (Eldridge), a driver for Meissen, was one of four drivers asked to haul a load of cattle. As Eldridge was helping load the cattle for transport, one cow charged, hit him in the back, and trampled him. Eldridge was knocked unconscious and taken to the hospital, where he was treated for a bruised lung and multiple bone fractures.