rvice in the house, such as cleaning,
cooking or washing. On one occasion, a porter in a saloon was sent
upstairs by the proprietor to wash the windows in the apartment where
the proprietor lived with his family. While thus engaged he fell to
the sidewalk and was injured. The court regarded him as a household
servant.

Many of the acts exclude from their protection casual employees. This
term is a difficult one to define, and has been omitted in many of the
acts. Where this is done all employees engaged in the usual course of
the trade, business, occupation, or profession of their employer, with
some exceptions, receive compensation. Ordinarily, an employment is
casual when it is for a single day, or by the hour, but does not apply
to one who is employed to render a service that recurs with some
regularity. Thus, one who is employed as a workman in a sawmill on
such days as it was in operation for four months was not a casual
employee. Casual employment in the Connecticut act means occasional or
incidental employment. In California, if the length of employment is
less than a week it is casual, even though contrary to agreement the
employee took more than a week to do the work for which he was hired,
and which a skillful employee could have finished within a week.

"The question whether an employment is casual must be determined with
reference to the scope and purpose of the hiring rather than with sole
regard to the duration and regularity of the service. One who enters
into a contract of employment for an entire season is not a casual
employee merely because he may be required to work for only short and
irregular periods." Thus, a longshoreman who is employed at a certain
sum per hour to help load a ship, having frequently rendered a similar
service on other occasions, is not a casual employee; nor is one who
keeps machinery and boats in order at an amusement park; nor is a boy
who is called at irregular intervals for service in a butcher's shop
when extra help is needed, or in the absence of a regular employee;
nor is one who is employed during a packing season to drive for a
packer whenever he is needed.

The compensation law does not apply to independent contractors. It is
difficult, however, to draw the line in many cases. Generally, an
independent contractor is one who exercises an independent employment
and contracts to do a piece of work according to his own method,
without being subject to the control of the