{"id":895777,"date":"2019-04-23T11:41:20","date_gmt":"2019-04-23T17:41:20","guid":{"rendered":"https:\/\/www.myconstructionexpert.com\/blog\/?p=895777"},"modified":"2019-04-23T11:41:26","modified_gmt":"2019-04-23T17:41:26","slug":"alarm-cries-wolf-involving-privette-doctrine","status":"publish","type":"post","link":"https:\/\/www.myconstructionexpert.com\/blog\/alarm-cries-wolf-involving-privette-doctrine\/","title":{"rendered":"Alarm Cries Wolf in California Case Involving Privette Doctrine"},"content":{"rendered":"\n

Garret Murai | California Construction Law Blog<\/a> | April 17, 2019<\/p>\n\n\n\n

It\u2019s one of the most quoted phrases in legal history: \u201cShouting fire in a [crowded] theater.\u201d<\/p>\n\n\n\n

It comes from the U.S. Supreme Court\u2019s landmark 1919 decision in\u00a0Schenck v.\u00a0U.S.<\/em>\u00a0and has come to stand for the proposition that not all speech, in particular dangerous speech, is protected by the First Amendment.<\/p>\n\n\n\n

The next case also involves a false alarm. But not of the First Amendment kind.<\/p>\n\n\n\n

In\u00a0Johnson v. The Raytheon Company, Inc.<\/em>, California Court of Appeal for the Second District, Case No. B281411 (March 8, 2019), a false alarm investigated by maintenance engineering staff led to a Privette Doctrine claim against a property owner when a ladder on which the maintenance staff was standing slipped on wet flooring.<\/p>\n\n\n\n

Johnson v. Raytheon<\/em><\/strong><\/p>\n\n\n\n

Lawrence Johnson worked as a maintenance engineer for ABM Facilities Services, Inc. ABM was hired by Raytheon Company, Inc. to staff the control room at one of Raytheon\u2019s facilities in Southern California. Among other things, control room staff monitored water cooling towers owned by Raytheon to ensure that the water in the cooling towers were maintained at minimum levels.<\/p>\n\n\n\n

Johnson worked the graveyard shift. At 2:50 a.m. on February 20, 2013, Johnson received a low water level alarm. He called his supervisor who, as one might expect someone to do when awakened at 3:00 a.m. in the morning,  told Johnson to do whatever he thought he should do.  In other words, Johnson was alone.<\/p>\n\n\n\n

At the time, Raytheon was undergoing a renovation project involving the removal and replacement of its water towers. System XT was the general contractor on the project, and two of its subcontractors, Brownco Construction Company, Inc. and Power Edge Solutions, Inc., were responsible for concrete work and the installation of electronic monitoring, respectively.<\/p>\n\n\n\n

Johnson, unable to resolve the alarm, walked outside to the water tower in question where he saw an extension ladder left by Brownco leaning against the cooling tower wall. The cooling tower used to have a platform ladder for access but it had been removed during the renovations. Oh, and also, it had been raining, so the ground was wet.<\/p>\n\n\n\n

I know what you\u2019re thinking. It\u2019s like the scene in pretty much any horror movie where the creepy music cues and you\u2019re nearly yelling at the screen, \u201cdon\u2019t open that door!,\u201d or in this case, \u201cdon\u2019t climb that ladder!\u201d Well, we all know what happens next.<\/p>\n\n\n\n

Johnson climbed the ladder even though (camera pan in) there was a sign on the ladder in all capital letters stating \u201cCAUTION\u201d and \u201cTHIS LADDER SECTION IS NOT DESIGNED FOR SEPARATE USE.\u201d Because it was dark, Johnson didn\u2019t see the warning.<\/p>\n\n\n\n

Johnson made his way up the ladder. When he took a look over the 8-foot wall of the cooling tower \u2026 wait for it \u2026 there was no problem with the water level. However, as he made his way down the ladder, it slid, causing Johnson to come tumbling down on top of the ladder where he sustained serious injuries.<\/p>\n\n\n\n

An investigation conducted after the accident revealed that the water level sensor installed by Power Edge had corroded and had to be replaced. That\u2019s luck for you.<\/p>\n\n\n\n

Johnson later sued Raytheon and Systems XT, alleging that Raytheon was liable because it retained control of the premises and that Systems XT ,as the general contractor, was liable for: (1) Power Edge\u2019s failure to properly install the water level sensor to prevent it from becoming corroded; and (2) Brownco\u2019s negligence in leaving its ladder out rather than putting it away.  Both Raytheon and Systems XT filed motions for summary judgment, which were granted by the trial court, and Johnson appealed.<\/p>\n\n\n\n

The Appeal<\/h3>\n\n\n\n

On appeal, the 2nd District Court of Appeal noted that the Privette Doctrine, named after the case in which it was first elucidated,\u00a0Privette v. Superior Court<\/em>\u00a0(1993) 5 Cal.4th 689, stands for the general principal that \u201ca hirer of an independent contractor was not liable for the negligence of the independent contractor.\u201d<\/p>\n\n\n\n

However, also noted the Court, the Privette Doctrine has given way to several exceptions including the following:<\/p>\n\n\n\n

  1. Negligent Exercise of Retained Control:<\/strong>\u00a0Under the negligent exercise of retained control exception, a hirer is liable for injuries sustained by an employee of an independent contractor if: (1) the hirer retains control over any part of the work; (2) the hirer negligently exercises that control; and (3) the hirer does so in a manner that affirmatively contributes to the employee\u2019s injury.\u201d\u00a0Hooker v. Department of Transportation<\/em>\u00a0(2002) 27 Cal.4th 198.<\/li>
  2. Hazardous Conditions on Property:<\/strong>\u00a0Under the hazardous conditions on property exception, a hirer is liable for injuries sustained by an employee of an independent contractor if: \u201d [(1)] the landowner knew, or should have known, of a latent or concealed preexisting hazardous condition on its property, [(2)] the contractor did not know and could not have reasonably discovered this hazardous condition, and [(3)] the landowner failed to warn the contractor about this condition.\u201d\u00a0Kinsman v. Unocal Corp.\u00a0<\/em>(2005) 37 Cal.4th 659.<\/li><\/ol>\n\n\n\n

    Raytheon Was Not Liable Under Hooker<\/em><\/strong><\/p>\n\n\n\n

    The Court of Appeal, focusing on the third factor of the negligent exercise of retained control exception, whether the hirer \u201caffirmatively contribute[d]\u201d to the employee\u2019s injury, held that Johnson had failed to show that Raytheon affirmatively contributed to his injuries because the evidence presented to the trial court was that Raytheon provided ABM employees with access to numerous other safe ladders that Johnson did not choose to use on the night in question:<\/p>\n\n\n\n

    After Raytheon pointed out the availability of other ladders in its respondent\u2019s brief, Johnson argued, in reply, that he had believed the ladder he found at the wall had been left by Raytheon, so had assumed it was safe, and that the area was not sufficiently well lit for him to have appreciated the danger posed by the partial extension ladder. While these arguments go some way to explaining why Johnson chose to use the partial extension ladder he discovered at the wall, they do not raise a triable issue of fact as to Raytheon\u2019s affirmative contribution to his injury. Raytheon did not represent that the partial extension ladder was a safe replacement for the platform ladder, nor did Raytheon promise to provide ABM employees with light fixtures at the water cooling tower \u2013 and Johnson cannot suggest for the first time in its reply brief on appeal that it did.<\/p><\/blockquote>\n\n\n\n

    Raytheon Was Not Liable Under Kinsman<\/strong><\/p>\n\n\n\n

    The Court of Appeal, focusing on the second factor of the hazardous conditions on property exception, that the contractor did not know and could not have \u201creasonably discovered\u201d the hazardous condition, held that Johnson could have reasonably discovered the hazard posed by the partial extension ladder by simply inspecting the ladder, and, once discovered, could have avoided the injury by using a different and safer ladder:<\/p>\n\n\n\n

    As we have discussed above in connection with the Hooker exception, it is undisputed that there were A-frame ladders available to Johnson. Thus, if the Brownco partial extension ladder were to be considered an obvious hazard, it cannot give rise to Raytheon\u2019s liability because knowledge of the hazard is not inadequate to prevent injury. Anyone with actual knowledge of the hazardous could have avoided it by obtaining an A-frame ladder instead.<\/p><\/blockquote>\n\n\n\n

    In other words, Johnson should have read the warning signs on the ladder.<\/p>\n\n\n\n

    Systems XT Was Not Liable For Negligence<\/strong><\/p>\n\n\n\n

    Johnson\u2019s claim against Systems XT was for negligence rather than an exception to the Privette Doctrine. Negligence, explained the Court of Appeals, involves the following: \u201c(1) a legal duty to use due care; (2) a breach of that duty; and (3) the breach as the proximate or legal cause of the resulting injury.\u201d<\/p>\n\n\n\n

    Johnson alleged that Systems XT breached two duties, namely, that Systems XT failed to ensure that Power Edge installed a water level sensor that would not create false alarms and  that System XT failed to ensure that Brownco safely secure its equipment including the partial extension ladder.<\/p>\n\n\n\n

    However, explained the Court of Appeals, while Johnson supported his allegation with contractual provisions contained in the various contracts and subcontracts between the parties, including a statement of work stating that the water cooling plant \u201cmust be a 24 x 7 \u2018Fail-Safe\u2019 operation,\u201d general provisions providing that \u201ccontractors are responsible for keeping their work areas orderly and neat . . and free of . . . hazardous,\u201d as well as specific provisions concerning ladders, which provided that \u201c[w]hen not in use, store the ladder in an appropriate storage place,\u201d Johnson had not shown that any of these contractual provisions created a duty owed by Systems XT to Johnson as a third-party beneficiary under these contractual provisions.<\/p>\n\n\n\n

    Conclusion<\/h3>\n\n\n\n

    Johnson<\/em> is an interesting case for reasons I think might surprise you. I believe the facts and law could have been interpreted and applied differently, fairly easily, by a different court. Instead of \u201cJohnson should have just read the dang warning signs on the ladder,\u201d I could see another court finding that the ladder shouldn\u2019t have been there in the first place, and because the cooling towers were still \u201con line\u201d Raytheon should have provided some means to provide safe access to them (after all, they had a platform ladder at one time, ostensibly for this very purpose). I could also see another court finding that  Systems XT did in fact breach a duty to Johnson because the safety provisions in the contracts was not intended to benefit some amorphous entity (i.e.<\/em>, Raytheon),  but among others, the employees of Raytheon who were working alongside an ongoing construction project.<\/p>\n\n\n\n

    But here\u2019s the thing. It wasn\u2019t another court. It was the 2nd District Court of Appeals. And in the last few years, the 2nd District Court of Appeals has come out with decisions scaling back exceptions to the Privette Doctrine, including last year\u2019s\u00a0Delgadillo v. Television Center, Inc.<\/em>\u00a0(2018) 20 Cal.App.5th 1078\u00a0case, and\u00a0Khosh v. Staples Construction Company, Inc.<\/em>\u00a0(2016) 4 Cal.App.5th 712 case decided two years earlier.<\/p>\n\n\n\n

    Perhaps we have an appellate court split in the making?<\/p>\n","protected":false},"excerpt":{"rendered":"

    Garret Murai | California Construction Law Blog | April 17, 2019 It\u2019s one of the most quoted phrases in legal history: \u201cShouting fire in a [crowded] theater.\u201d It comes from the U.S. Supreme Court\u2019s landmark 1919 decision in\u00a0Schenck v.\u00a0U.S.\u00a0and has come to stand for the proposition that not all speech, in particular dangerous speech, is… Continue reading Alarm Cries Wolf in California Case Involving Privette Doctrine<\/span><\/a><\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","enabled":false},"version":2}},"categories":[10721,8782],"tags":[9895,361,9884],"class_list":["post-895777","post","type-post","status-publish","format-standard","hentry","category-insurance","category-personal-injury","tag-advise-consult","tag-personal-injury","tag-privette-doctrine","entry"],"jetpack_publicize_connections":[],"yoast_head":"\nAlarm Cries Wolf in California Case Involving Privette Doctrine - 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