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Workers’ Compensation Was Employee’s Exclusive Remedy For Cycling Injuries Sustained While Leaving Work But Still On Campus
Rose Jones worked as the Director of Scholarship Opportunities at the University of California, Irvine campus. At the end of her workday, she left her office and began biking home. A section of the bike path contained a trench that the university had cordoned off with caution tape. Jones swerved to avoid the obstacle, fell off her bike, and was injured. She sued UC Irvine for maintaining a dangerous condition.
UC Irvine moved to have the case dismissed through summary judgment. UC Irvine argued that Jones could only seek recovery for her injury through workers’ compensation. Under the workers’ compensation exclusivity rule, workers’ compensation is generally an employee’s sole remedy against the employer for injuries sustained in the course of employment. An employee’s commute is not usually covered by workers’ compensation. However, UC Irvine argued that Jones’s injuries were subject to workers’ compensation under the premises line rule. The premises line rule extends the course of employment until an employee leaves the employer’s premises. Jones’s injuries occurred while she was still on UC Irvine’s premises.
The trial court agreed with UC Irvine and granted it’s motion for summary judgement. Jones appealed the trial court’s ruling. Jones argued that a triable issue remained as to whether the premises line rule applied to the circumstances of her accident.
The court of appeal disagreed with Jones and upheld the trial court decision. The court of appeal concluded that Jones’s injuries occurred within the course of her employment, so the workers’ compensation exclusivity rule barred her claim. It made no difference that the campus was large, that UC Irvine did not dictate Jones’s means of transportation, or that Jones was leaving work rather than arriving at work. The court of appeal pointed out that there is a triable issue of whether the premises line applies when employees live on premises. However, Jones did not live on the UC Irvine campus. The court of appeal affirmed the trial court’s grant of summary judgment.
Jones v. Regents of University of California (2023) 97 Cal.App.5th 502.