Wright v. St. of CA
233 Cal. App. 4th 1218
| Cal. Ct. App. | 2015Background
- Wright, a San Quentin correctional officer, lived in a State‑owned rental unit on prison grounds (voluntarily, paid market rent); he worked at San Quentin before moving into the unit.
- On December 14, 2010, while walking from his unit toward the Donner Unit to begin his shift, a concrete stair allegedly collapsed and Wright fell, sustaining injuries.
- Wright filed a workers’ compensation claim, received benefits (medical and disability payments), and later filed a tort (premises liability) suit against the State for negligent maintenance of the stairs.
- The State moved for summary judgment, arguing workers’ compensation was Wright’s exclusive remedy under the premises line rule (employment begins when entering employer premises); trial court granted summary judgment.
- Wright argued (1) he was still commuting to his place of work (going and coming rule), (2) the premises line should not automatically apply to employees who reside on employer property, invoking the bunkhouse rule, and (3) the lease/indemnity provisions showed the State did not intend universal coverage by workers’ compensation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether workers’ compensation is the exclusive remedy for Wright’s on‑premises injury | Wright: He was commuting and had not reached his business/workplace; living on premises was voluntary so the bunkhouse rule shouldn’t apply | State: Entry onto employer premises triggers employment (premises line); exclusivity applies; Wright already accepted WC benefits | Reversed summary judgment — triable issue exists whether injury arose in course of employment; bunkhouse rule and facts create a dispute |
| Applicability of the premises line when employee resides on employer property | Wright: The premises line cannot be applied without considering that he was a tenant living on the premises; living there does not automatically make all on‑premises injuries compensable | State: No distinction between employer premises and business premises; premises line controls regardless of residency | Court: Premises line does not automatically control for resident employees; bunkhouse rule must be considered, creating triable issues |
| Whether the bunkhouse rule applies given Wright’s landlord‑tenant relationship with the State | Wright: He lived there voluntarily, not as condition/benefit of employment, so bunkhouse rule may preclude WC coverage (i.e., it creates a factual inquiry) | State: Relationship is landlord/tenant so bunkhouse rule is inapplicable (citing Rosen logic) | Court: Trial court erred by ignoring bunkhouse rule; tenant status was subsidiary and employee relationship predominated, so bunkhouse analysis is required |
| Whether lease indemnity/insurance provisions defeat tort claim | Wright: Lease terms indicate State did not intend workers’ compensation to insure all on‑premises injuries; supports a dual‑capacity/contractual duty argument | State: Lease irrelevant because injury occurred off the rental doorstep and premises line governs | Court: Lease provisions support existence of triable factual issues about the parties’ intent and obligations; summary judgment improper |
Key Cases Cited
- Santa Rosa Junior College v. Workers’ Comp. Appeals Bd., 40 Cal.3d 345 (premises line rule; employment begins upon entry to employer premises)
- Price v. Workers’ Comp. Appeals Bd., 37 Cal.3d 559 (premises line and presumption of compensability after entry)
- Vaught v. State of California, 157 Cal.App.4th 1538 (application of bunkhouse rule where residence was an employment benefit or work necessity)
- Associated Oil Co. v. Industrial Acc. Com., 191 Cal. 557 (early bunkhouse rule discussion; voluntary residence on employer property not automatically compensable)
- Larson v. Industrial Acc. Com., 193 Cal. 406 (bunkhouse rule where residence was required or part of compensation)
- State Compensation Ins. Fund v. Industrial Acc. Com., 194 Cal. 28 (bunkhouse application where lodging was part of compensation and use was required)
- General Ins. Co. v. Workers’ Comp. Appeals Bd., 16 Cal.3d 595 (premises line rationale and limits of going and coming rule)
- Lefebvre v. Workers’ Comp. Appeals Bd., 106 Cal.App.3d 745 (discussing factual nature of when employee enters course of employment)
- Lewis v. Workers’ Comp. Appeals Bd., 15 Cal.3d 559 (background on going and coming rule and premises examples)