Gravelin v. Satterfield, 200 Cal. App. 4th 1209 (2011)

Gary Gravelin was injured while installing a satellite dish on the roof of a residence. Although Gravelin received workers’ compensation benefits from his employer, he sued the homeowners. The trial court granted summary judgment to the homeowners on the ground that in the absence of an exception to the doctrine enunciated in Privette v. Superior Court, 5 Cal. 4th 689 (1993), Gravelin was limited to the remedy provided by workers’ compensation. Gravelin argued that the “preexisting hazardous condition” exception applied, but the trial court disagreed. The Court of Appeal affirmed dismissal on summary judgment. Cf. Castillo v. Toll Bros., Inc., 197 Cal. App. 4th 1172 (2011) (minimum wage – not the prevailing wage – is the standard for determining whether hirer of independent contractor is liable for violating Labor Code § 2810).