Rose Jones worked as the director of scholarship opportunities at the University of California, Irvine. One day, when leaving her office at the University’s science library, Jones walked her bike a short distance to the bike path, mounted her bike, and began riding toward her home. After about 10 seconds, Jones reached a trench, cordoned off with orange posts and caution tape. Upon noticing the obstacle, she swerved and attempted to brake, but fell off her bike and sustained injuries.
After the accident, Jones sued the University for negligence and premises liability, among other claims. Following discovery, the University moved for summary judgment, claiming that Jones’ injuries occurred within the course of her employment and therefore workers’ compensation was the exclusive remedy for her claim.
The University argued that Jones was still on the University’s premises when she sustained her injuries, and therefore was still within the scope of her employment. Jones argued that she was leaving work, rather than arriving, within an area designated for public use and using the means of her choice to commute across UCI’s large campus. Jones argued that these factors supported that she was not within the scope of her employment.
The trial court granted the University’s motion for summary judgment, concluding that Jones’ injuries occurred within the course of her employment and that she did not exercise due care at the time of the accident. Jones appealed.
On appeal, Jones argued that (1) Jones was leaving work, rather than arriving; (2) her means of commute were not employer-designated, and her route was not reserved for employees but also used by students and the general public; and (3) the University’s campus was large.
The Court of Appeals explained that under the “premises line rule,” an employee’s commute terminates and the course of their employment commences when the employee enters the employer’s premises. In other words, once the employee enters the premises, an injury is presumed to be compensable until the employee leaves the employer’s premises.
The Court of Appeals concluded that Jones’ injuries occurred on UCI’s campus, undisputedly owned by the University, just after she left her workstation. Under these circumstances, the premises line rule brought Jones’ injuries within the workers’ compensation scheme.
The Court of Appeals was not persuaded by Jones’ arguments. The premises line rule applies whether an employee is leaving work or arriving at work, and traveling via roads that are used by the general public and non-employees does not change the analysis. Furthermore, although the University’s campus is large, the “premises line rule” allows a sharp line of demarcation so that courts do not have to make subjective determinations as to where employment begins.
The Court of Appeals affirmed the trial court’s ruling.
Jones v. Regents of the University of California (Oct. 31, 2023) __Cal.App.5th__ [2023 Cal. App. LEXIS 917].
Note: This case serves as an important reminder that injuries that occur as employees are leaving work can still be within the scope of their employment. Here, workers’ compensation acted as the sole remedy for this employee’s injury, reducing the overall liability to the University.