Lantz v. WCAB, 226 Cal. App. 4th 298 (2014)

Lieutenant Seth Patrick Lantz, a 33-year-old correctional officer at Pleasant Valley State Prison in Coalinga, California, was killed in an automobile accident on his way home from work. Lantz’s widow, on behalf of herself and her four children, applied for workers’ compensation benefits, contending that Lantz sustained the fatal injury during the course of his employment. Before the fatal accident, Lantz had been “held over” for an extra shift so that he had worked a total of 16 hours. The Court of Appeal affirmed the decision of the WCAB that the hold-over shift was not “extraordinary” and, therefore, workers’ compensation benefits were properly denied to Lantz’s survivors. See also Young v. WCAB, 2014 WL 2875839 (Cal. Ct. App. 2014) (correctional sergeant’s off-duty injury sustained while performing his regular exercise regimen was compensable where county required officers to maintain themselves in good physical condition); Kesner v. Superior Court, 226 Cal. App. 4th 251 (2014) (nephew of employee who allegedly contracted mesothelioma from exposure to friable asbestos while in his uncle’s home could proceed with products liability lawsuit against uncle’s former employer); Haver v. BNSF Ry. Co., 226 Cal. App. 4th 1104 (2014) (wrongful death action based on premises liability associated with exposure to employer-sourced asbestos was properly dismissed).