In early July 2023, the Supreme Court of California released an important decision in the case of Kuciemba v. Victory Woodworks, Inc., No. S274191. The state’s highest court determined that an employer was not liable for the COVID-19 illness contracted by the spouse of one of its employees. The decision has important implications for workers’ compensation claims and workplace injury/illness liability in California. In this article, our Sacramento workers’ compensation defense lawyer provides a comprehensive review of the case.
Work Illness Case Overview: Kuciemba v. Victory Woodworks, Inc.,
The Facts
Robert Kuciemba, an employee at Victory Woodworks in San Francisco, reportedly contracted COVID-19 while on the job. There was unanimous agreement regarding the origin of the infection, and no legal contention was present. Unfortunately, Mr. Kuciemba’s wife, who was medically vulnerable, also caught the virus. She was hospitalized for over a month as a result. The husband-and-wife couple initiated a legal claim against the employer.
The Core Legal Debate
Within the case of Kuciemba v. Victory Woodworks, Inc., two pivotal legal questions were brought to the forefront:
- Whether the derivative-injury doctrine would stop the spouse of an employee—who became infected with COVID-19 at work and transmitted it to their partner—from seeking a legal claim against the employer.
- Whether an employer is legally obliged to take ordinary care to mitigate the transmission of COVID-19 to the households of their employees.
California Supreme Court Decision
The court responded negatively to both aforementioned questions. Indeed, the Supreme Court of California ruled that the spouse of an employee who had contracted COVID-19 was not legally precluded from initiating legal proceedings against the employer of the spouse.
However, the state’s highest court also ruled the employer is not bound by a duty of care toward the spouse or other family members of an employee. Such an obligation, the court reasoned, would place an overly substantial burden upon businesses and organizations operating within California.
The Implications for Work Injury Defense in California
The ruling in this case bore significant implications for employers across California. In theory, the court’s decision might have exposed employers to a multitude of lawsuits stemming from family members of employees affected by COVID-19 or other diseases. However, the court ascertained that employers possess limited control over activities outside their workplace.
While adherence to state regulations concerning COVID-19 safety and general workplace safety is mandatory, employers are typically not held responsible if an illness is transmitted by an employee to a family member. Nevertheless, the court also delineated that the law does not prevent a family member from pursuing a third-party liability lawsuit against an employer of a relative.
Speak to Our Sacramento, CA Workers’ Compensation Defense Attorney Today
At Yrulegui & Roberts, our Sacramento workers’ compensation defense lawyers are diligent, experienced, and solutions-forward advocates for our clients. If you have any questions about a workers’ compensation case, please contact us today. We provide workers’ compensation defense services in Sacramento and throughout the region, including in Fresno, Bakersfield, and Salinas.
