Wright v. State of Cal., 183 Cal. Rptr. 3d 135 (Cal. Ct. App. 2015)

Monnie Wright was a correctional officer at San Quentin State Prison who lived on the premises of the prison in a unit he rented from the State of California. Wright was injured when he fell in the course of his walk from his home to his place of work at the prison. Following his injury, Wright sought and obtained workers’ compensation benefits exceeding $137,000. Wright then filed a civil suit against the State, alleging premises liability for an allegedly defectively constructed and dangerously maintained stair that crumbled beneath him. The State moved for summary judgment on the ground that workers’ compensation provided the exclusive remedy for Wright’s claim because he was injured on the employer’s premises (the “premises line rule”). The trial court granted the State’s motion for summary judgment, but the Court of Appeal reversed, finding a triable issue of material fact as to whether Wright’s injury arose out of and in the course of his employment. See also Schultz v. WCAB, 232 Cal. App. 4th 1126 (2015) (premises line rule applied and going-and-coming rule did not preclude award of workers’ compensation benefits to employee injured in a traffic accident on a United States Air Force base not generally open to the public).