California Court: Workers’ Compensation Claim Only Remedy for Employee Hurt While Leaving Workplace

On October 31, 2023, the California Fourth District Court of Appeal ruled in favor of an employer in the case of Jones v. Regents of the University of California. The court determined that an employee—who was injured while riding her bike leaving on campus after work—was limited to filing a workers’ compensation claim. In this blog post, our Bakersfield workers’ compensation defense law firm highlights key things to know about this case, including the implications for employers and insurers.

Case Review: Jones v. Regents of the University of California


An employee at the University of California, Irvine (UCI) suffered injuries from a bike accident on university grounds while commuting home. The employee—who was serving as the director of scholarship opportunities—had just left her office at UCI’s science library, mounted her bike, and encountered an obstructed trench. Subsequently, she sued the university for negligence. However, her lawsuit was initially dismissed by a trial court.

Legal Issue

The central legal issue revolved around whether the employee’s injuries, sustained during her commute on the university premises, were compensable under workers’ compensation. If so, that would make a workers’ compensation claim the sole legal remedy she had against the university (her employer). Typically, injuries incurred during an employee’s commute are outside this scope. However, the “premises line” rule—which was a crucial point in this case—holds that an employee’s work-related coverage extends until they leave the employer’s premises. The employee challenged this, arguing that her commute, the nature of the path used, and the size of the campus differentiated her situation from other work injury claims.

Court Decision

The appeals court upheld the trial court’s decision, ruling that the workers’ compensation exclusivity rule applied, barring the employee’s lawsuit. It emphasized that the accident occurred on UCI’s premises and was thus within the course and scope of her employment. The court applied the “premises line” rule, which indicates that an employee’s work relation and the accompanying compensations extend until they physically leave the employer’s premises. The court dismissed the employee’s arguments that her departure from work, the shared use of the route, and the campus’s size were irrelevant in applying the premises line rule. In doing so, the appellate court cites precedence from the California Supreme Court.

Lesson for Employers

In California, a workers’ compensation claim is typically the sole remedy that an injured employee has against their own employer. Commuting injuries are not covered by workers’ compensation. However, if an employee is still under the employer’s premises and is starting the journey home, that may still give rise to a workers’ compensation claim under California’s “premises rule.”

Get Help From a Bakersfield Workers’ Comp Defense Law Firm

At Yrulegui & Roberts, our Bakersfield workers’ compensation defense lawyers are standing by, ready to protect your best interests. If you have any questions about the exclusive remedy provision of workers’ compensation coverage, we are here to help. Contact us today to set up your completely confidential initial case review. Our law firm provides workers’ compensation defense representation in Bakersfield, Kern County, and throughout the wider area.