Boyle's Wisconsin Safe-Place Law

Chapter One: Nature of Safe-Place Law
    (o) Insurance Coverage
It has been held that an insurance policy insuring an employer or owner against liability for negligence covers such employer or owner in the event of safe-place liability inasmuch as such liability is merely a species of negligence rather than the basis of an independent cause of action. [132] Likewise indemnity agreements between defendants in a safe-place action are valid. [133]

Conversion Table Wis. 2d or Wis. to N.W. 2d or N.W.

132. Ermis v. Federal Windows Mfg. Co., 7 Wis. 2d 549, 555 (1959). See also Bloss v. Rural Mut. Casualty Co., 270 Wis. 127 (1955).

133. Barrons v. J. H. Findorff & Sons, Inc., 89 Wis. 2d 444 (1979); Dykstra v. Arthur G. McKee & Co., 92 Wis. 2d 17 (Ct. App. 1979); Dykstra v. McKee & Co., 100 Wis.2d 120, 131 (1981): "We conclude, however, that this shifting of responsibility through either the principles of common law indemnity or contractural indemnity is not what is meant by the statement that the duties under the safe place statute are nondelegable."

Revised October 20, 2001