Indiana Code

Ind. Code § 22-4-8-1 (2026)

Definition

✓ current as of May 2026
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     Sec. 1. (a) "Employment," subject to the other provisions of this section, means service, including service in interstate commerce performed for remuneration or under any contract of hire, written or oral, expressed or implied.

     (b) Services performed by an individual for remuneration shall be deemed to be employment subject to this article irrespective of whether the common-law relationship of master and servant exists, unless and until all the following conditions are shown to the satisfaction of the department:

(1) The individual has been and will continue to be free from control and direction in connection with the performance of such service, both under the individual's contract of service and in fact.

(2) The service is performed outside the usual course of the business for which the service is performed.

(3) The individual:

(A) is customarily engaged in an independently established trade, occupation, profession, or business of the same nature as that involved in the service performed; or

(B) is a sales agent who receives remuneration solely upon a commission basis and who is the master of the individual's own time and effort.

     (c) The term also includes the following:

(1) Services performed for remuneration by an officer of a corporation in the officer's official corporate capacity.

(2) Services performed for remuneration for any employing unit by an individual:

(A) as an agent-driver or commission-driver engaged in distributing products, including but not limited to, meat, vegetables, fruit, bakery, beverages, or laundry or dry-cleaning services for the individual's principal; or

(B) as a traveling or city salesman, other than as an agent-driver or commission-driver, engaged upon a full-time basis in the solicitation on behalf of, and the transmission to, the individual's principal (except for sideline sales activities on behalf of some other person) of orders from wholesalers, retailers, contractors, or operators of hotels, restaurants, or other similar establishments for merchandise for resale or supplies for use in their business operations.

     (d) For purposes of subsection (c)(2), the term "employment" shall include services described in subsection (c)(2)(A) and (c)(2)(B) only if all the following conditions are met:

(1) The contract of service contemplates that substantially all of the services are to be performed personally by such individual.

(2) The individual does not have a substantial investment in facilities used in connection with the performance of the services (other than in facilities for transportation).

(3) The services are not in the nature of a single transaction that is not part of a continuing relationship with the person for whom the services are performed.

Formerly: Acts 1947, c.208, s.801; Acts 1971, P.L.355, SEC.13. As amended by P.L.108-2006, SEC.6.

 

Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1983–2024 · leading case: Bloomington Area Arts Council v. Dep't of Workforce Dev., Unemployment Ins. Appeals, 821 N.E.2d 843 (Ind. Ct. App. 2005).
Bloomington Area Arts Council v. Dep't of Workforce Dev., Unemployment Ins. Appeals, 821 N.E.2d 843 (Ind. Ct. App. 2005). · cites it 34× “al has been and will continue to be free from control and direction in connection with the performance of such service, both under his contract of service and in fact; (B) such service is performed outside the usual course of the business for which the service is performed; and…”
Co. v. Indiana Dep't of Workforce Dev., 86 N.E.3d 204 (Ind. Ct. App. 2017). · cites it 10× “The LALJ concluded that, pursuant to the test detailed in Indiana Code section 22-4-8-1 of the Act, Claimant had been an employee of Company starting in 2014 and was therefore entitled to receive unemployment benefits related to her work.”
Q.D.-A., Inc. v. Indiana Dep't of Workforce Dev., 114 N.E.3d 840 (Ind. 2019). · cites it 10× “See Ind. Code § 22-4-8-1 (b). After looking at all the evidence, the Department determined that Q.”
Furr v. Review Bd. of the Indiana Emp. Sec. Div., 482 N.E.2d 790 (Ind. Ct. App. 1985). · cites it 8× “Neither provision (A) or (C) of the Ind.Code § 22-4-8-1 test was met. Irvin urges that because it was understood that Furr's status was that of an independent contractor and because no taxes were withheld, th Revie Board's decision should be upheld.”
Circle Health Partners, Inc. v. Unemployment Ins. Appeals of the Indiana Dep't of Workforce Dev., 47 N.E.3d 1239 (Ind. Ct. App. 2015). · cites it 8× “determining the nurses and phlebotomists are employees of CHP within the meaning of Ind. Code § 22-4-8-1 . For purposes of determining when an employer is liable for unemployment taxes, employment means “service .”
Q. D.-A., Inc. v. Indiana Dep't of Workforce Dev., 96 N.E.3d 620 (Ind. Ct. App. 2018). · cites it 43× “Ind. Code § 22-4-8-1 (b). Thus, pursuant to the terms of the statute, all workers are presumed to be employees until an employer demonstrates that all three factors are fulfilled.”
Jug's Catering, Inc. v. Indiana Dep't of Workforce Dev., Unemployment Ins. Bd., 714 N.E.2d 207 (Ind. Ct. App. 1999). · cites it 6× “Nor does Jug’s challenge the ALJ’s analysis of the facts under I.C. § 22-4-8-1. 1 Therefore, as we see no error on our own review, we conclude the ALJ did not erroneously determine the chefs and servers hired by Jug’s to be employees for purposes of unemployment contributions.”
Now Courier, Inc. v. Review Bd. of Indiana Dep't of Workforce Dev., 871 N.E.2d 384 (Ind. Ct. App. 2007). · cites it 2× “However, in section 22-4-8-3, the statutory scheme then provides that “employment” for the purpose of eligibility “shall not include” certain other specified services. I.C. § 22-4-8-3. An additional provision states that “employment” for the Article 4 unemployment compensation…”
Turner Transp., Inc. v. Indiana Emp. Sec. Bd., 448 N.E.2d 300 (Ind. Ct. App. 1983). · cites it 4× “(Turner) appeals the decision of a liability referee for the Indiana Employment Security Division that drivers hired by Turner were "employees" under Ind.Code 22-4-8-1, and that Turner thus owed unemployment taxes demanded by the Division.”
CINTEMP, Inc. v. Unemployment Ins. Review Bd. of the Indiana Dep't of Workforce Dev., 717 N.E.2d 988 (Ind. Ct. App. 1999). · cites it 4× “In its Brief of Appellant, CTI makes the sole allegation that it was not an "employer” as defined by Ind. Code § 22-4-8-1 (a) for purposes of unemployment compensation.”
The Law Off. of Deborah Agard v. Unemployment Ins. Appeals of the Indiana Dep't of Workforce Dev. (Ind. Ct. App. 2012). · cites it 6× “(3) The individual: (A) is customarily engaged in an independently established trade, occupation, profession, or business of the same nature as that involved in the service performed; or (B) is a sales agent who receives remuneration solely upon a commission basis and who is the…”
T.W. v. Review Bd. of the Indiana Dep't of Workforce Dev., 952 N.E.2d 312 (Ind. Ct. App. 2011). · cites it 2× “” 4 Ind.Code § 22-4-8-1. Clearly, as in Siddiqi , if the claimant is receiving income from self-employment, the claimant will be, at a minimum, subject to a reduction in benefits.”
— Ind. Code § 22-4-8-1(a) — 3 cases
Bloomington Area Arts Council v. Dep't of Workforce Dev., Unemployment Ins. Appeals, 821 N.E.2d 843 (Ind. Ct. App. 2005). “al has been and will continue to be free from control and direction in connection with the performance of such service, both under his contract of service and in fact; (B) such service is performed outside the usual course of the business for which the service is performed; and…”
Jug's Catering, Inc. v. Indiana Dep't of Workforce Dev., Unemployment Ins. Bd., 714 N.E.2d 207 (Ind. Ct. App. 1999). “Nor does Jug’s challenge the ALJ’s analysis of the facts under I.C. § 22-4-8-1. 1 Therefore, as we see no error on our own review, we conclude the ALJ did not erroneously determine the chefs and servers hired by Jug’s to be employees for purposes of unemployment contributions.”
Turner Transp., Inc. v. Indiana Emp. Sec. Bd., 448 N.E.2d 300 (Ind. Ct. App. 1983). “(Turner) appeals the decision of a liability referee for the Indiana Employment Security Division that drivers hired by Turner were "employees" under Ind.Code 22-4-8-1, and that Turner thus owed unemployment taxes demanded by the Division.”
— Ind. Code § 22-4-8-1(a)(A) — 1 case
Turner Transp., Inc. v. Indiana Emp. Sec. Bd., 448 N.E.2d 300 (Ind. Ct. App. 1983). “(Turner) appeals the decision of a liability referee for the Indiana Employment Security Division that drivers hired by Turner were "employees" under Ind.Code 22-4-8-1, and that Turner thus owed unemployment taxes demanded by the Division.”
— Ind. Code § 22-4-8-1(b) — 3 cases
Q.D.-A., Inc. v. Indiana Dep't of Workforce Dev., 114 N.E.3d 840 (Ind. 2019). “See Ind. Code § 22-4-8-1 (b). After looking at all the evidence, the Department determined that Q.”
Q. D.-A., Inc. v. Indiana Dep't of Workforce Dev., 96 N.E.3d 620 (Ind. Ct. App. 2018). “Ind. Code § 22-4-8-1 (b). Thus, pursuant to the terms of the statute, all workers are presumed to be employees until an employer demonstrates that all three factors are fulfilled.”
The Law Off. of Deborah Agard v. Unemployment Ins. Appeals of the Indiana Dep't of Workforce Dev. (Ind. Ct. App. 2012). “(3) The individual: (A) is customarily engaged in an independently established trade, occupation, profession, or business of the same nature as that involved in the service performed; or (B) is a sales agent who receives remuneration solely upon a commission basis and who is the…”
— Ind. Code § 22-4-8-1(b)(1) — 2 cases
Q.D.-A., Inc. v. Indiana Dep't of Workforce Dev., 114 N.E.3d 840 (Ind. 2019). “See Ind. Code § 22-4-8-1 (b). After looking at all the evidence, the Department determined that Q.”
Q. D.-A., Inc. v. Indiana Dep't of Workforce Dev., 96 N.E.3d 620 (Ind. Ct. App. 2018). “Ind. Code § 22-4-8-1 (b). Thus, pursuant to the terms of the statute, all workers are presumed to be employees until an employer demonstrates that all three factors are fulfilled.”
— Ind. Code § 22-4-8-1(b)(2) — 1 case
Q.D.-A., Inc. v. Indiana Dep't of Workforce Dev., 114 N.E.3d 840 (Ind. 2019). “See Ind. Code § 22-4-8-1 (b). After looking at all the evidence, the Department determined that Q.”
— Ind. Code § 22-4-8-1(b)(3) — 1 case
Q.D.-A., Inc. v. Indiana Dep't of Workforce Dev., 114 N.E.3d 840 (Ind. 2019). “See Ind. Code § 22-4-8-1 (b). After looking at all the evidence, the Department determined that Q.”
— Ind. Code § 22-4-8-1(b)(3)(A) — 1 case
The Law Off. of Deborah Agard v. Unemployment Ins. Appeals of the Indiana Dep't of Workforce Dev. (Ind. Ct. App. 2012). “(3) The individual: (A) is customarily engaged in an independently established trade, occupation, profession, or business of the same nature as that involved in the service performed; or (B) is a sales agent who receives remuneration solely upon a commission basis and who is the…”
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