Answer:
D. The window washer was entitled to no recovery based on his status as an independent contractor.
Explanation:
The reason is that the employer is liable to have all safety measures in place to safeguard the employee from any type of injury at work. If despite all these safety measures, the employee gets injured then he is entitled to workers' compensation.
However, the employer is not liable to compensate independent contractors for accidents as the duty of care is not upon the employer in the case of independent contractors which means that the independent workers are obliged to take all necessary precautions to avoid any injury because it will not be compensated by the employer. Thus, the employer is not liable to compensate independent contractors and option D is correct.