Independent Contractor or Agent Frankie and Trena Gibbs and Joel and Madeira Glenn were members of the same church, which both couples attended. The church held a fundraiser whereby members would help other members with projects and the member for whom the work was done would make a donation to the church’s youth ministry. As part of the fundraiser, Frankie Gibbs, who had no experience using a chainsaw, asked Joel Glenn, who was experienced with using a chainsaw, to trim branches on a tree on Gibbs’s property. When Glenn arrived at Gibbs’s property with his own chainsaw and ladder, Gibbs showed Glenn which limbs on the tree he wanted trimmed. Glenn climbed to the very top of an A-type ladder, straddled the ladder—one foot on each side—and began trimming the tree. However, after making a cut on a limb, the limb snapped off and hit the top of the ladder, knocking the ladder backward. Glenn fell forward, head first, and landed on his back. Glenn died from the fall. Madeira Glenn sued the Gibbses to recover damages, alleging that her deceased husband was an agent of the Gibbses, and that as principals the Gibbses had breached the ordinary duty of care they owed to Glenn as an invitee upon their property. Gibbs defended, asserting that Glenn was an independent contractor with a duty of his own to make certain his work area was safe, to take all precautions, and to exercise ordinary care for his own safety. Was Joel Glenn an independent contractor or an agent of the Gibbses? Glenn v. Gibbs, 746 S.E.2d 658, 2013 Ga. App. Lexis 639 (Court of Appeals of Georgia, 2013)