The California Court of Appeal ruled on August 26, 2026, in the case of Schurman Family Company TIC v. Superior Court of Alameda County (docket number A174194). The court's decision clarifies the application of the Privette doctrine, which generally protects employers from liability for injuries suffered by independent contractors while on the job. This ruling is significant as it impacts how liability is determined for injuries involving independent contractors, particularly in landlord-tenant relationships.
The case arose when Phuokhao Bounxaysana, an employee of an independent contractor, was injured while working on a warehouse roof owned by Schurman Family Company TIC. Bounxaysana fell through a skylight while attempting to access equipment for Verizon, the tenant that had leased space in the warehouse. Following the injury, Bounxaysana sued both Verizon and Schurman for negligence and premises liability.
Schurman sought summary judgment, arguing that the Privette doctrine should shield it from liability because it had not directly hired Bounxaysana's employer, the independent contractor L.D. Strobel. However, the trial court denied Schurman's motion, stating that the Privette doctrine did not apply to landlords like Schurman. This led Schurman to appeal the decision, prompting the Court of Appeal to review the matter.
In its ruling, the Court of Appeal reversed the trial court's decision, stating that Schurman was indeed protected under the Privette doctrine. The court emphasized that the doctrine extends beyond the direct hirer of an independent contractor to include those in the 'chain of delegation.' The court stated, 'Because it is undisputed that the Privette doctrine applied to protect the direct hirer in this case, we conclude that same doctrine also protects Schurman from liability for Bounxaysana’s on the job injuries.'
This ruling has implications for landlords and property owners in California, as it clarifies that they can be shielded from liability for injuries suffered by independent contractors working on their properties, provided there is a clear chain of delegation. The court's decision aligns with previous rulings that have recognized the importance of delegating responsibility for workplace safety to independent contractors.
The court's opinion also highlighted the broader legal context surrounding the Privette doctrine, which was established to prevent landowners and hirers from being held liable for injuries that occur due to the negligence of independent contractors. The court noted that the Privette doctrine is based on the premise that independent contractors have the authority to control the manner in which their work is performed, and therefore, they assume responsibility for workplace safety.
Going forward, this ruling reinforces the notion that landlords and property owners are not automatically liable for injuries that occur on their premises when independent contractors are involved. It also sets a precedent for similar cases, indicating that the Privette doctrine can extend to non-hiring parties within the chain of delegation.
As for what’s next, the decision can potentially be appealed to the California Supreme Court, but there is no indication at this time whether the parties will seek further review. The ruling may also influence other pending cases involving the application of the Privette doctrine and liability issues related to independent contractors.