## Facts

- Eugene Collins worked for Glen Day as a farm/agricultural employee.
- Collins broke his right leg in a work-related accident on February 11, 1989.
- Collins sought workers’ compensation benefits for medical expenses (about $12,000) and lost wages, asserting weekly earnings of $140 plus the value of housing.
- Day had not elected workers’ compensation coverage and relied on Ind. Code § 22-3-2-9(a), which excludes farm/agricultural employees and their employers from the Workers’ Compensation Act.
- The parties stipulated to the operative facts, leaving only the legal validity of the exemption under the Indiana Constitution.

## Issues

1. Whether excluding farm/agricultural employees from the Indiana Workers’ Compensation Act violates the Indiana Constitution’s Privileges and Immunities Clause (Art. I, § 23).
2. Whether Art. I, § 23 claims are analyzed under federal Equal Protection standards or under an independent state constitutional test.
3. Whether the agricultural exemption is reasonably related to inherent class characteristics and applied uniformly to those similarly situated.

## Decision

- The Indiana Supreme Court held that Art. I, § 23 imposes requirements independent of the federal Equal Protection Clause.
- The court adopted a two-part standard for reviewing statutory classifications under Art. I, § 23.
- Applying that standard, the court upheld Ind. Code § 22-3-2-9(a)’s agricultural exemption as constitutional.
- The court affirmed the Full Workers’ Compensation Board’s dismissal of Collins’s claim for benefits.

## Legal Principles

- Indiana Constitution Art. I, § 23 is not coextensive with the federal Equal Protection Clause; federal doctrine may be persuasive but does not control state constitutional analysis.
- A statutory classification under Art. I, § 23 is valid if:
  - the disparate treatment is reasonably related to inherent characteristics that distinguish the classes; and
  - the preferential or disparate treatment is uniformly applicable to all persons similarly situated within the relevant class.
- The agricultural-worker exemption satisfies Art. I, § 23 where the legislature could rationally treat agricultural work as a distinct class based on sector characteristics (including operational and enforcement considerations) and the exemption applies across the class rather than selectively.

## Conclusion

The Indiana Supreme Court sustained the Workers’ Compensation Act’s agricultural exemption and established an independent two-part framework for evaluating legislative classifications under Indiana’s Privileges and Immunities Clause, requiring a reasonable relationship to inherent class characteristics and uniform application within the class.


Collins v. Day, 644 N.E.2d 72 (Ind. 1994)