Von Beltz v. Stuntman, Inc

In Von Beltz v. Stuntman, Inc. (1989) 207 Cal. App. 3d 1467, a stunt driver who was seriously injured in the making of the movie, "Cannonball Run," sued director Hal Needham and his loan-out company. Needham claimed he was employed by the same production company, Cannonball Productions, Inc., that employed the injured plaintiff and thus was a co-employee, limiting the plaintiff's recovery to worker's compensation benefits. Meanwhile, Needham's loan-out company asserted that Needham was not its agent, making it not liable on a respondeat superior theory. The issue was put to the jury which found that Needham's employment relationship was with his loan-out company, not with Cannonball Productions. The Court of Appeal affirmed, concluding sufficient evidence supported the jury's findings. The fact that in one case a stunt driver was an independent contractor of a production company does not make all stunt drivers independent contractors of all production companies.