In Jones v. Regents of the University of California, ordered published November 28, 2023, the Fourth District Court of Appeal, Division 3 affirmed summary judgment for the defendant regents. An employee of the regents who worked on the UC Irvine campus was riding home from her work on a bicycle. Ten seconds into her ride, while still on campus, she swerved and attempted to brake to avoid a trench, and fell off her bike, sustaining injuries. She sued the Regents for maintaining a dangerous condition of public property. The trial court granted the regents summary judgment, ruling that the plaintiff's exclusive remedy was workers' compensation.
The appellate court affirmed. The premises line rule provides that after the worker enters the employer's premises, injury is generally presumed subject to workers' compensation until the employee leaves the premises. Because the plaintiff's injuries occurred on the employer's campus, just after she left her workstation, her injuries occurred in the course and scope of her employment as a matter of law. The facts that she was leaving work, that she was not using an employer-designated vehicle or route, and that the campus is large do not raise triable issues.
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