October 1998, Pablo Urena worked for Worker's Mania Inc., a temporary employment agency, and was assigned to work at Theta Products Inc. in Rhode Island. He was directed to stamp metal picture frames using a power press. On his second day at Theta, Urena returned from a coffee break and noticed that a piece of metal he had left on the press was askew. As he reached for the metal, the press came down on his hand, seriously injuring one of his fingers. Urena required surgery and physical therapy and could not return to work until March 1999. He received workers'-comp benefits from Worker's Mania. He also sued Theta, alleging that the company failed to maintain a safe workplace and that it was negligent in the maintenance of the power press.
Theta asked the Rhode Island trial court to grant summary judgment for it, contending that it was immune from suit for Urena's injuries under the state's Workers' Compensation Act. The court agreed and dismissed the case against Theta.
Urena appealed to the Rhode Island Supreme Court, but lost. The court said that under Rhode Island law, Theta was a "special employer," or one that contracts for services from a "general employer" — a temporary employment company like Worker's Mania. Both a general and a special employer were considered to be an employer under the Workers' Comp Act, and were protected from lawsuits by employees injured on the job. Urena's damages were limited to the workers'-compensation benefits he had already received, the court concluded.
Urena v. Theta Products Inc.,