In a premises liability case before the California Court of Appeal, the court reversed a grant of summary judgment based on the remaining triable issue of whether an employee’s injury arose out of and in the scope of his employment.
Monnie Wright worked as a correctional officer at San Quentin State Prison, and he lived on the San Quentin premises. He rented a unit from his employer, the State of California. He lived there voluntarily, since it was not a condition of his employment with the State. He paid market rate rent and did not receive a discount or benefit for living on the property.
While walking to work in the early morning, Mr. Wright fell and was injured when a concrete step collapsed beneath him. He sought and received workers’ compensation in the form of medical expenses and disability payments.
Mr. Wright then filed a premises liability lawsuit against the State. The State moved for summary judgment on the basis that Mr. Wright was exclusively entitled to workers’ compensation as his remedy. They based their argument on the “premises line rule,” which states that an employee begins the employment relationship once they enter the employer’s premises. The State also stated that Mr. Wright had already received over $137,000 in workers’ compensation benefits, which showed that the injuries arose out of and occurred in the scope of his employment.
Mr. Wright argued that the State did not show that his claim was barred by the exclusivity rule of workers’ compensation. He alleged that there was a question of fact regarding whether he was injured in the course of his employment. He further argued that the “bunkhouse rule” precluded summary judgment. The bunkhouse rule states that an employee-resident is covered by workers’ compensation if the employment contract or the work requires that the employee reside on employer-owned premises. Mr. Wright also argued that his lease agreement demonstrated that he was not to be covered by workers’ compensation while living in the residence.
The trial court agreed with the premises line rule and granted the motion for summary judgment, making no mention of the bunkhouse rule. After Mr. Wright moved for a new trial, the trial court stated that the bunkhouse rule was inapplicable. The trial court denied the motion and relied on the premises line exception to the going and coming rule. Mr. Wright appealed.
On appeal, the court stated their standard of review in analyzing a grant of summary judgment. Independently, the court asks whether undisputed facts have been shown that would negate the plaintiff’s claims. The State in this case had the burden of showing there were no triable issues of material fact regarding whether Mr. Wright’s injury arose out of and in the course of his employment.
First, the court stated that the general rule is that an employee injured while commuting to or from work is not eligible for workers’ compensation. The reason is that an employee on their way to work is not rendering a service to their employer at the time of the accident. Due to criticism, courts have adopted the premises line rule. This stated that the employment relationship begins when the employee enters the employer’s premises. Here, the court stated that the trial court applied this rule without considering whether Mr. Wright’s residency on employer-owned property necessitated a limitation of the premises rule.
Here, the court stated that the bunkhouse rule applied. There remained a triable issue of material fact regarding whether Mr. Wright was acting in the course of his employment when he was injured. He was not required to live on the San Quentin grounds. His contract did not require it, nor did he receive a benefit from his employer for living there. In this case, the employment relationship was the main relationship between Mr. Wright and the State, not a landlord-tenant relationship.
The court also stated the lease agreement required Mr. Wright to obtain comprehensive coverage through public liability insurance, naming the State as the insured. The indemnity provision clause stated that the tenant agrees to hold the owner harmless in claims for damages. The court stated that the lease made clear the State did not intend to insure Mr. Wright for all injuries suffered on San Quentin grounds. If, the court contended, the State believed that Mr. Wright was covered by workers’ compensation at all times, it would not insert these provisions into the lease.
The court concluded that there was a genuine issue of material fact regarding whether Mr. Wright’s injury arose out of and in the course of his employment. The summary judgment was reversed.
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More Blog Posts:
California Court of Appeals Applies Premises Line Rule to Determine Employee is Entitled to Workers’ Compensation Benefits, Southern California Injury Lawyer Blog, August 10, 2015
California Court of Appeals Reverses Judgment for City as Design Immunity Does Not Apply, Southern California Injury Lawyer Blog, September 8, 2015