coming and going rule (California) · Go Syfert
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coming and going rule in California

8 California opinions name it 2 courts 1969–2020 0 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Hinojosa v. Workmen's Compensation Appeals Boardgreen
cal · 1972 · cited in 2 California opinions naming this issue, 2018–2018
2 sentences

2018Appeals Bd. (1972) 8 Cal.3d 150 , 157, 104 Cal.Rptr. 456 , 501 P.2d 1176 ( Hinojosa ).) "[T]his means not just any trivial benefit to the employer, but a benefit 'sufficient enough to justify making the employer responsible for the risks inherent in the travel.' ( Blackman, supra, [ 233 Cal.App.3d at p. 604 , 284 Cal.Rptr. 491 ].)" ( Jorge, supra, 3 Cal.App.5th at pp. 397-398, 207 Cal.Rptr.3d 586 .) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen's Comp.

2018Appeals Bd. (1972) 8 Cal.3d 150 , 157, 104 Cal.Rptr. 456 , 501 P.2d 1176 ( Hinojosa ).) "[T]his means not just any trivial benefit to the employer, but a benefit 'sufficient enough to justify making the employer responsible for the risks inherent in the travel.' ( Blackman, supra, [ 233 Cal.App.3d at p. 604 , 284 Cal.Rptr. 491 ].)" ( Jorge, supra, 3 Cal.App.5th at pp. 397-398, 207 Cal.Rptr.3d 586 .) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen's Comp.

12
Beckwith v. Dahlgreen
calctapp · 2012 · cited in 2 California opinions naming this issue, 2017–2017
2 sentences

2017When it becomes clear that the plaintiffs interests are entitled to legal protection against the conduct of the defendant, the mere fact that the claim is novel will not of itself operate as a bar to the remedy.’ ” (Beckwith v. Dahl (2012) 205 Cal.App.4th 1039, 1050 [ 141 Cal.Rptr.3d 142 ], citing Prosser & Keeton, Torts (5th ed. 1984) § 1, p. 4, fn. omitted.) Finally, we note that the public policy objectives of the respondeat superior doctrine support a finding that vicarious liability may attach to Modern Alloys under these facts.

2017When it becomes clear that the plaintiffs interests are entitled to legal protection against the conduct of the defendant, the mere fact that the claim is novel will not of itself operate as a bar to the remedy.’ ” (Beckwith v. Dahl (2012) 205 Cal.App.4th 1039, 1050 [ 141 Cal.Rptr.3d 142 ], citing Prosser & Keeton, Torts (5th ed. 1984) § 1, p. 4, fn. omitted.) Finally, we note that the public policy objectives of the respondeat superior doctrine support a finding that vicarious liability may attach to Modern Alloys under these facts.

12
Wilson v. Workers' Compensation Appeals Boardgreen
cal · 1976 · cited in 1 California opinions naming this issue, 2020–2020
1 sentence

2020Appeals Bd. (1976) 16 Cal.3d 181, 185 [Transporting the materials “may have been essential to applicant’s employment, but unless such materials require a special . . . mode of transportation . . . their mere transport does not warrant exception from the going and coming rule.”].) Assuming for the sake of argument that using a specially equipped vehicle is alone sufficient to create an exception to the coming and going rule, there is no evidence Steger had such a vehicle.

11
Joyner v. Workmen's Compensation Appeals Boardgreen
calctapp · 1968 · cited in 1 California opinions naming this issue, 2018–2018
1 sentence

2018These cases held that where an employee is injured in a traffic accident on his commute home, while carrying equipment for his job, the employer relationship continued such that the employee's injuries were compensable and not *144 subject to the coming and going rule. ( Joyner, at p. 476, 72 Cal.Rptr. 132 ; Lane, at p. 527, 331 P.2d 99 .) These cases address a different issue than the one before us and therefore we find them inapposite.

11
Lane v. Industrial Accident Commissiongreen
calctapp · 1958 · cited in 1 California opinions naming this issue, 2018–2018
1 sentence

2018These cases held that where an employee is injured in a traffic accident on his commute home, while carrying equipment for his job, the employer relationship continued such that the employee's injuries were compensable and not *144 subject to the coming and going rule. ( Joyner, at p. 476, 72 Cal.Rptr. 132 ; Lane, at p. 527, 331 P.2d 99 .) These cases address a different issue than the one before us and therefore we find them inapposite.

11
Harvey v. D & L Construction Co.green
calctapp · 1967 · cited in 1 California opinions naming this issue, 2017–2017
1 sentence

2017Co. (1967) 251 Cal.App.2d 48, 49 [possible business errand while employee was providing another employee a ride home from an out-of-state worksite].) 8 the coming and going rule and the business errand exception). “„[T]he law of torts is anything but static, and the limits of its development are never set.

11
Hinman v. Westinghouse Electric Co.green
cal · 1970 · cited in 1 California opinions naming this issue, 2016–2016
1 sentence

2016(Hinman, supra, 2 Cal.3d at p. 962, fn. 3 .) Though not identical, the two versions of the rule are closely related.

11
Richards v. Metropolitan Life Insurancegreen
cal · 1941 · cited in 1 California opinions naming this issue, 1969–1969
2 sentences

1969Co. (1941) 19 Cal.2d 236, 239-244 [ 120 P.2d 650 ]; Robinson v. George, supra, 16 Cal.2d at pp. 244-245; Boynton v. McKales, supra, 139 Cal.App.2d at p. 789 .) Plaintiffs also rely on Breland v. Traylor Engineering etc. Co. (1942) 52 Cal.App.2d 415, 423-425 [ 126 P.2d 455 ], Breland , indeed, is a direct precedent, since it is a tort case which excludes application of the coming and going rule where the employee-driver receives a transportation allowance from the employer.

1969Co. (1941) 19 Cal.2d 236, 239-244 [ 120 P.2d 650 ]; Robinson v. George, supra, 16 Cal.2d at pp. 244-245; Boynton v. McKales, supra, 139 Cal.App.2d at p. 789 .) Plaintiffs also rely on Breland v. Traylor Engineering etc. Co. (1942) 52 Cal.App.2d 415, 423-425 [ 126 P.2d 455 ], Breland , indeed, is a direct precedent, since it is a tort case which excludes application of the coming and going rule where the employee-driver receives a transportation allowance from the employer.

11
Breland v. Traylor Engineering & Manufacturing, Co.green
calctapp · 1942 · cited in 1 California opinions naming this issue, 1969–1969
2 sentences

1969Co. (1941) 19 Cal.2d 236, 239-244 [ 120 P.2d 650 ]; Robinson v. George, supra, 16 Cal.2d at pp. 244-245; Boynton v. McKales, supra, 139 Cal.App.2d at p. 789 .) Plaintiffs also rely on Breland v. Traylor Engineering etc. Co. (1942) 52 Cal.App.2d 415, 423-425 [ 126 P.2d 455 ], Breland , indeed, is a direct precedent, since it is a tort case which excludes application of the coming and going rule where the employee-driver receives a transportation allowance from the employer.

1969Co. (1941) 19 Cal.2d 236, 239-244 [ 120 P.2d 650 ]; Robinson v. George, supra, 16 Cal.2d at pp. 244-245; Boynton v. McKales, supra, 139 Cal.App.2d at p. 789 .) Plaintiffs also rely on Breland v. Traylor Engineering etc. Co. (1942) 52 Cal.App.2d 415, 423-425 [ 126 P.2d 455 ], Breland , indeed, is a direct precedent, since it is a tort case which excludes application of the coming and going rule where the employee-driver receives a transportation allowance from the employer.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Blackman v. Great American First Savings Bank green
calctapp · 1991
2 sentences

2018Appeals Bd. (1972) 8 Cal.3d 150 , 157, 104 Cal.Rptr. 456 , 501 P.2d 1176 ( Hinojosa ).) "[T]his means not just any trivial benefit to the employer, but a benefit 'sufficient enough to justify making the employer responsible for the risks inherent in the travel.' ( Blackman, supra, [ 233 Cal.App.3d at p. 604 , 284 Cal.Rptr. 491 ].)" ( Jorge, supra, 3 Cal.App.5th at pp. 397-398, 207 Cal.Rptr.3d 586 .) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen's Comp.

2018Appeals Bd. (1972) 8 Cal.3d 150 , 157, 104 Cal.Rptr. 456 , 501 P.2d 1176 ( Hinojosa ).) "[T]his means not just any trivial benefit to the employer, but a benefit 'sufficient enough to justify making the employer responsible for the risks inherent in the travel.' ( Blackman, supra, [ 233 Cal.App.3d at p. 604 , 284 Cal.Rptr. 491 ].)" ( Jorge, supra, 3 Cal.App.5th at pp. 397-398, 207 Cal.Rptr.3d 586 .) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen's Comp.

22018–2018
Jorge v. Culinary Institute of America green
calctapp · 2016
2 sentences

2018Appeals Bd. (1972) 8 Cal.3d 150 , 157, 104 Cal.Rptr. 456 , 501 P.2d 1176 ( Hinojosa ).) "[T]his means not just any trivial benefit to the employer, but a benefit 'sufficient enough to justify making the employer responsible for the risks inherent in the travel.' ( Blackman, supra, [ 233 Cal.App.3d at p. 604 , 284 Cal.Rptr. 491 ].)" ( Jorge, supra, 3 Cal.App.5th at pp. 397-398, 207 Cal.Rptr.3d 586 .) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen's Comp.

2018Appeals Bd. (1972) 8 Cal.3d 150, 157 (Hinojosa).) “[T]his means not just any trivial benefit to the employer, but a benefit ‘sufficient enough to justify making the employer responsible for the risks inherent in the travel.’ ( Blackman, supra, [223 Cal.App.3d] at p. 604.)” ( Jorge, supra, 3 Cal.App.5th at pp. 397–398.) The California Supreme Court recognized the required vehicle exception to the coming and going rule in Smith v. Workmen’s Comp.

22018–2018
Smith v. Workmen's Compensation Appeals Board green
cal · 1968
2 sentences

2018App. Bd. (1968) 69 Cal.2d 814 , 73 Cal.Rptr. 253 , 447 P.2d 365 ( Smith ), holding that an employee is acting in the course of employment during his or her commute when the employer requires the employee to bring a car to work.

2018App. Bd. (1968) 69 Cal.2d 814 , 73 Cal.Rptr. 253 , 447 P.2d 365 ( Smith ), holding that an employee is acting in the course of employment during his or her commute when the employer requires the employee to bring a car to work.

22018–2018
D a & S Oil Well Servicing, Inc., a Corporation v. James P. Mitchell, Secretary of Labor, United States Department of Labor green
ca10 · 1958
1 sentence

2018Further, we note that in both of these cases, the employee was not being paid by his employer for his commute time when the accident happened. ( Ibid .) Finally, plaintiffs rely on federal cases construing the Portal-to-Portal Act, even though that act contains an exemption for travel time missing from California law. ( Morillion, supra, 22 Cal.4th at p. 590 , 94 Cal.Rptr.2d 3 , 995 P.2d 139 .) In D A & S Oil Well Servicing, Inc. v. Mitchell (10th Cir. 1958) 262 F.2d 552 , the question was whether the time an employee spent driving a truck mounted with heavy, specialized equipment (30,000-poun

12018–2018
Morillion v. Royal Packing Co. green
cal · 2000
2 sentences

2018Further, we note that in both of these cases, the employee was not being paid by his employer for his commute time when the accident happened. ( Ibid .) Finally, plaintiffs rely on federal cases construing the Portal-to-Portal Act, even though that act contains an exemption for travel time missing from California law. ( Morillion, supra, 22 Cal.4th at p. 590 , 94 Cal.Rptr.2d 3 , 995 P.2d 139 .) In D A & S Oil Well Servicing, Inc. v. Mitchell (10th Cir. 1958) 262 F.2d 552 , the question was whether the time an employee spent driving a truck mounted with heavy, specialized equipment (30,000-poun

2018Further, we note that in both of these cases, the employee was not being paid by his employer for his commute time when the accident happened. ( Ibid .) Finally, plaintiffs rely on federal cases construing the Portal-to-Portal Act, even though that act contains an exemption for travel time missing from California law. ( Morillion, supra, 22 Cal.4th at p. 590 , 94 Cal.Rptr.2d 3 , 995 P.2d 139 .) In D A & S Oil Well Servicing, Inc. v. Mitchell (10th Cir. 1958) 262 F.2d 552 , the question was whether the time an employee spent driving a truck mounted with heavy, specialized equipment (30,000-poun

12018–2018
Boynton v. McKales green
calctapp · 1956
1 sentence

1969Co. (1941) 19 Cal.2d 236, 239-244 [ 120 P.2d 650 ]; Robinson v. George, supra, 16 Cal.2d at pp. 244-245; Boynton v. McKales, supra, 139 Cal.App.2d at p. 789 .) Plaintiffs also rely on Breland v. Traylor Engineering etc. Co. (1942) 52 Cal.App.2d 415, 423-425 [ 126 P.2d 455 ], Breland , indeed, is a direct precedent, since it is a tort case which excludes application of the coming and going rule where the employee-driver receives a transportation allowance from the employer.

11969–1969

Statutes the citing opinions construe

CA § Cal. Labor Code § 3600 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 68 (1998–2025) TX 26 (1986–2026) PA 12 (1986–2024) ID 9 (1986–2015) CA 8 (1969–2020) NC 6 (2001–2011) KY 5 (2013–2023) FL 5 (1990–2024) UT 5 (1995–2008) CT 5 (2000–2018) WY 4 (1983–1986) AR 4 (1959–1987) MD 3 (1994–1998) AZ 3 (1984–2026) NM 2 (1960–1991) NJ 2 (1996–2001) WA 2 (2008–2014) MI 2 (1981–2020) MS 2 (2016–2019) NH 2 (1981–2022) VA 2 (2025–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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