Gale, an umpire, was a member of the Greater Washington Softball Umpires Association. During a game which Gale was officiating, a player objected to his decision on a play. The player then struck Gale with a baseball bat, causing injuries to Gale’s neck, hip, and leg. Gale claimed that he was an employee of the association and, as such, sought workers’ compensation for his injuries. The association asserted that its members were independent contractors. It based this assertion on the fact that the umpires had full charge and control of the games, and that the association did not direct the worker in the performance or manner in which the work was done. The evidence presented showed

(a) That the umpires were paid by the association from fees collected from the teams;

(b) That the umpires, while assigned to the games by the association, were not obligated to accept the assignments;

(c) That the association conducted clinics, administered written examinations, and required members to wear designated uniforms while officiating; and

(d) That the umpires had to meet with the approval of committees of the association who observed a member officiating during a probationary period. Under these circumstances, do you believe Gale was an employee of the association or an independent contractor? (Gale v. Greater Washington Softball Umpires Association, 311 A.2d 817)