Employee Hurt In Bike Accident On Campus Is Limited To Workers’ Compensation

CATEGORY: Client Update for Public Agencies
CLIENT TYPE: Public Employers
DATE: Jan 08, 2024

Rose Jones worked at the University of California (UC) at the Irvine campus.  After work one day, Jones left her office, walked her bike to a campus bike path and began to ride home.  Jones reached a trench that was cordoned off with orange posts and caution tape.  Jones swerved and attempted to brake but fell off her bike and got hurt.

Jones sued the UC for her injuries.  The UC moved for summary judgment, claiming that Jones’s injuries occurred within the course of her employment and therefore workers’ compensation was her exclusive remedy.  The trial court granted UC’s motion for summary judgment.  Jones appealed.

The California Court of Appeal affirmed.  In order to “create a sharp line of demarcation” as to when the employee’s commute terminates and the course of employment commences, courts have adopted the “premises line rule,” which provides that the employment relationship generally commences once the employee enters the employer’s premises.  The Court further explained that this rule applies when an employee is coming both to and from work.

The Court held that the premises line rule applies if an employee is injured on an employer’s campus just after leaving their workstation for the day.  Workers’ compensation is the employee’s exclusive remedy in this case.

Jones v. Regents of University of California, 97 Cal.App.5th 502 (2023).

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