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Vaught v. State of California
filed December 18, 2007, Fourth District, Div. One
Cite as 2007 SOS 7430

Court Affirms Decision On State Worker’s Torts Case

Marck Vaught had accepted an offer to work as a park ranger for the state. As an incentive, he was allowed to relocate his family and live in the state-owned ranch house. The Vaughts moved into the house and discovered a water leak in one of the bathrooms. State workers were called in but to repair the leaks while the Vaughts were out of the house. The workers were unable to repair the leak. On their return, Vaught slipped and fell in the wet bathroom floor. Marck Vaught filed a case against the state for his injuries, for the state’s alleged negligence and failure to make the house ‘habitable for human occupation’. State lawyers countered that Vaught’s injuries are not work-related and that the state worker was not bound by workers’ compensation exclusive remedy since he rented the house as a tenant.

On trial, the lower court granted summary judgment for the state. It also found the worker’s compensation exclusivity barred Vaught’s actions.

When brought up for review the issue of whether Vaught’s injuries are work-related or not was taken up. The issue of the so-called bunk house rule was also discussed.

On appeal, the Fourth District, Division One Appeals court affirmed the decision of the trial court and found Vaught’s injuries to be work-related. It also ruled on the following issues

•    that the bunk house rule does not apply in the case although Vaught had signed an agreement to rent the house to the state
•    the award of compensation applies even though Vaught was injured on his day off as long as his stay in the employer’s property is a condition of his employment.