In Wright v. State of California (No. A139034, filed 1/30/2015) the First District Court of Appeal held a state correctional officer, who lived on state owned property adjacent to his place of employment, was not precluded, as a matter of law, from asserting a civil claim against his employer for injuries that occurred while he was walking from his residence to his place of employment.
Monnie Wright was a correctional officer at San Quentin Prison. He voluntarily lived on the premises pursuant to a lease with the State of California. Wright’s commute to work was a walk from his rented unit approximately 10 feet to a common area staircase, then across two streets, through a park, and along a sidewalk to the entrance of the prison. All the property he traveled over was owned by the State, Wright’s employer.
On the date of injury, as Wright neared the bottom of the first staircase, a concrete step collapsed beneath him causing him to fall and suffer injuries. Several days later, Wright filed for and received workers’ compensation benefits.
After qualifying for workers’ compensation, Wright sued the State, alleging a single cause of action for premises liability. The State filed a motion for summary judgment asserting workers’ compensation was the exclusive remedy for Wright’s injuries. Wright opposed the motion, alleging he was not in the course of his employment at the time of the incident. Wright urged the Court to apply the “bunkhouse rule,” a judicially created loosening of the statutory requirement that a compensable injury must arise out of and occur in the course of the employment. The bunkhouse rule extends workers’ compensation benefits to an employee who is injured in his or her living quarters, though it does not occur while performing an employment task, provided that the employment contract requires the employee to reside at the employers’ premises.
The trial court granted the motion without considering whether the bunkhouse rule applied. Instead, the trial court concluded the “premises line rule” (a limitation on the “going and coming” exclusion) was applicable. It reasoned that since Wright was injured on premises owned by his employer, he was within the course of employment, and workers’ compensation was his sole remedy. After the court entered judgment, Wright moved for a new trial claiming the court had erred in not considering the bunkhouse rule argument. The trial court denied the motion, concluding “[t]he bunkhouse rule is inapplicable to his case.”
The First District Court of Appeal reversed, holding there was a genuine issue of material fact as to whether Wright was in the course of employment at the time of the injury. Specifically, the Court traced the history of the bunkhouse rule and noted it should have been applied by the trial court instead of the “premises line rule.” The Court cited Associated Oil Co. v. Industrial Acc. Com. (1923) 191 Cal. 557 (“Associated Oil“); the earliest case citing the bunkhouse rule. The Court of Appeal concluded that like in Associated Oil, Wright was injured at a time when he was not at work and was neither required to work nor to be on the premises.
The Court also relied heavily on the fact the State could not effectively argue it anticipated workers’ compensation would cover all potential injuries to Wright that occurred on the premises. This was evident from the language of the lease agreement, which specifically called for Wright to purchase a policy of liability insurance and hold the State harmless for any injuries arising on the premises that were not otherwise caused by the negligence of the State.
The Court of Appeal remanded the case to the district court to resolve the factual issue of whether Wright was in the course of employment at the time of the incident.
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