Mill Street Church of Christ v. Hogan Introduction:
All relationships have the ability to strongly affect people, especially individuals that were not initially invested in such relationships. In a principal agent relationship, there is an established responsibility that the agent can act on the behalf or instead of the principle; however, what happens when there is a third party affected by the decisions of that relationship? In the case of Mill Street Church of Christ v. Hogan, we are able to examine the differences between actual express and implied authority are applied and how these authorities hold the defendant liable to the third party.
Mill Street Church of Christ v. Hogan, Mill Street Church of Christ and State Automobile
Mutual Insurance Company appealed the New Worker’s Compensation Board’s decision, which had stated that Bill Hogan was indeed in an agent principal relationship with Mill Street Church of Christ; therefore is liable for the compensation of Sam Hogan, the respondent’s injury. In the case, the Church had decided to repaint their walls and hired Bill Hogan to complete the task.
Hogan had been painting the walls himself, however he reached a difficult portion of the building and decided that he needed additional help to finish painting. He spoke with Dr. David
Waggoner, an Elder of the church, who stated that Hogan could possibly hire Gary Petty to help; however Dr. Waggoner also mentioned that Petty would be difficult to contact. There was no effort to state that the Church strongly recommended Hogan hire Petty. Later on, Bill Hogan decided to approach his brother, Sam Hogan, to help him finish the painting. Bill had explained the details of the position and Sam had accepted. Mill Street Church of Christ had hired Bill
Hogan for many projects, in addition, allowed him to hire extra help if needed which included participation from Sam Hogan. After Sam started working, a leg of the ladder broke which led to
Sam falling and breaking his arm. Sam, then, applied for Worker’s Compensation against the
Church.
Although Mill Street Church of Christ can argue that there was no actual express authority, which is when the authority is declared in clear, direct and definite terms because the Church did not actually state what kinds of authorities Bill Hogan could exercise. The only objective stated was that the Church wanted to repaint the building and hired Hogan to complete the task.
However, implied authority, which is when the agent can do what is reasonably necessary to carry out express authority and accomplish the objects of the agency, can be applied
. For example, the Church provided Hogan with the supplies to paint; however any other materials he needed, he would purchase from the Hardware Store and charge the church’s account. The agent, Hogan, did what was reasonably necessary to complete the task by purchasing needed equipment. So therefore, when Hogan had been painting the walls himself then reached the difficult portions of the Church, he needed extra assistance to finish the Church’s objective. This can be categorized as a reasonably necessary action because he could not complete the task himself.
In addition, apparent authority, which arises from what the principal causes the third party to believe. An agent has apparent authority when the principal, by either word or action, causes a third party reasonably to believe that the agent has authority to act, even

though the agent has no express or implied authority. One way of the principal expressing apparent authority to the agent is by patterns of conduct. As stated before, the Mill Street
Church of Christ had previously hired Bill Hogan for many projects, in addition, acknowledged and consented that Bill had hired his brother, Sam Hogan. Therefore, these actions had led Bill to believe that he could hire his brother, Sam, because Bill had the authority to do so many times before this certain project.
In addition, the Mill Street Church of Christ is a disclosed principal, which is a principal whose identity is known by the third party at the time the contract is made by the agent therefore the agent has no contractual liability for the nonperformance of the principal or the third party. Sam Hogan acknowledged that he was working for the Mill Street
Church of Christ because Bill Hogan explained that the Church would be reimbursing Sam for his work. This clears Bill Hogan from liability.
As stated before, the Mill Street Church of Christ vs. Hogan case tried to appeal the New
Board’s decision; however the decision held. Because the agent, Bill Hogan, help implied authority and apparent authority, the Court stated that Bill had the authority to hire the respondent, Sam Hogan, therefore held the Mill Street Church of Christ liable for Sam Hogan’s
Worker’s Compensation. Although many people would greatly appreciate the direct properties of express authority, this case exemplified the beneficial landscape of the importances between actual authority, which is express and implied, and apparent authority. Because Mill Street Church of
Christ displayed implied and apparent authority through their interactions with Bill Hogan, the court was able to establish a principal agent relationship. This relationship forced the Church to be liable for Sam Hogan, a third party of the agency. It is important to question, if the Church’s objective was met without difficulty, would there be a case? These laws are created to regulate both the benefits and difficulties of such relationships, which intend to protect both parties.