Wrenne v. JA Sutherland CA3

CourtCalifornia Court of Appeal
DecidedJune 2, 2026
DocketC102531
StatusUnpublished

This text of Wrenne v. JA Sutherland CA3 (Wrenne v. JA Sutherland CA3) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wrenne v. JA Sutherland CA3, (Cal. Ct. App. 2026).

Opinion

Filed 6/2/26 Wrenne v. JA Sutherland CA3 NOT TO BE PUBLISHED

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (Shasta)

LINDA WRENNE et al., C102531 Plaintiffs and Appellants, (Super. Ct. No. 24CV0204643) v.

JA SUTHERLAND, INC., et al., Defendants and Respondents.

The California Workers’ Compensation Act (WCA; Lab. Code, § 3200, et seq.)1 is a comprehensive statutory scheme governing the compensation employers must pay employees for injuries suffered in the course and scope of their employment. (Charles J. Vacanti, M.D., Inc. v. State Comp. Ins. Fund (2001) 24 Cal.4th 800, 810 (Vacanti); King v. CompPartners, Inc. (2018) 5 Cal.5th 1039, 1046, 1051 (King).) As a general rule, the workers’ compensation system is the sole or exclusive remedy available for an employee’s work-related injuries, including death. (Kuciemba v. Victory Woodworks, Inc. (2023) 14 Cal.5th 993, 1006 (Kuciemba).) This rule is known as the workers’ compensation exclusivity rule. (See Singh v. Southland Stone, U.S.A., Inc. (2010) 186 Cal.App.4th 338, 365.)

1 Undesignated statutory references are to the Labor Code.

1 In March 2022, Kevin Wrenne, an employee of a Taco Bell in Redding, was fatally stabbed in the restaurant’s parking lot during an unpaid 30-minute meal break. Wrenne’s parents and his estate (collectively, plaintiffs) filed this wrongful death and survival action against “Taco Bell Corp.” and others, asserting claims for premises liability and negligence. Plaintiffs appeal from the judgment entered after the trial court sustained the demurrers to the complaint without leave to amend. Plaintiffs argue the trial court erred by relying on the “premises line rule” to conclude that their claims were barred as a matter of law under the workers’ compensation exclusivity rule. In other words, plaintiffs contend the trial court erroneously determined that Wrenne’s injuries fell within the exclusive remedy provisions of the WCA, such that they were precluded from bringing the instant civil action. We see no error and affirm.

FACTUAL AND PROCEDURAL BACKGROUND Because this appeal challenges an order sustaining two demurrers, we summarize the facts underlying this action assuming, as we must, the truth of all properly pleaded allegations in the complaint. (Heckart v. A-1 Self Storage, Inc. (2018) 4 Cal.5th 749, 753.) Complaint In 2022, Wrenne was employed by J.A. Sutherland, Inc. (J.A. Sutherland) and Andrew Hennan, Sr. (Hennan),2 the owners and/or operators of a Taco Bell fast-food restaurant located at 1220 Market Street in Redding. Nielsen Motor Co. (Nielsen Motor) owned the real property and leased it to J.A. Sutherland. Wrenne was a crew member of the subject Taco Bell.

2 According to J.A. Sutherland and Hennan, plaintiffs erroneously sued “Andrew Hennan Sr.”

2 On the evening of March 28, 2022, Wrenne was fatally stabbed in his employer’s parking lot in an unprovoked attack by Brent Close, “a transient individual.” At the time of the stabbing, Wrenne was on a 30-minute unpaid lunch (or meal) break. After clocking out, Wrenne went to the Taco Bell parking lot and sat down on the curb. Thereafter, Close approached Wrenne and stabbed him five times in the neck and chest. Close was subsequently arrested and found guilty of murder. In March 2024, plaintiffs (i.e., Wrenne’s parents and his estate) brought this wrongful death and survival action against J.A. Sutherland, Nielsen Motor Co., Taco Bell Corp., and Hennan. The complaint alleged two causes of action: (1) dangerous and defective condition of premises (i.e., premises liability), and (2) negligence. Plaintiffs’ claims were based on defendants’ failure to maintain safe premises and to take reasonable safety precautions to protect against foreseeable criminal acts of third parties (e.g., provide proper lighting, suitable resting areas for employees, security guards, surveillance cameras). According to plaintiffs, the fatal stabbing was foreseeable because the Taco Bell was in a high crime area and there was an extensive history of violent threats and acts at the restaurant, including “stabbings.” In support of their position, plaintiffs alleged that more than 1,000 calls for service were made to the Redding Police Department in the 10 years prior to Wrenne’s death, including 282 calls for service in the preceding three years, 99 of which were made by Taco Bell employees. Demurrers In June 2024, J.A. Sutherland and Hennan filed a demurrer, which primarily argued that the complaint was subject to dismissal for lack of subject matter jurisdiction because plaintiffs’ claims fell within the exclusive jurisdiction of the state workers’ compensation system, as Wrenne was fatally stabbed in his employer’s parking lot during the course and scope of his employment. In making this argument, J.A. Sutherland and Hennan relied on the “premises line rule,” which, in their view, made workers’ compensation the sole or exclusive remedy for the injuries Wrenne suffered on his

3 employer’s premises during an authorized unpaid break from his work shift. In other words, plaintiffs claimed that the instant action was barred by the workers’ compensation exclusivity rule. In July 2024, Taco Bell Corp. and Taco Bell Franchisor, LLC3 filed a separate demurrer, which also relied on the “premises line rule” to argue that the claims alleged in the instant action were barred by the workers’ compensation exclusivity rule. In August 2024, after the trial court granted Nielson Motor’s motion to strike the punitive damage allegations and plaintiffs decided not to amend their complaint, the demurring parties refiled their respective demurrers. In September 2024, plaintiffs filed separate written oppositions to the demurrers. Trial Court’s Ruling In October 2024, after a hearing, the trial court sustained the demurrers without leave to amend. In so ruling, the court stated, in relevant part, as follows: “[Section] 3600 et seq limits employer liability for injuries alleged to have been sustained by employees arising out of, and in the course of employment. See ... § 3602(a). In such instances, worker’s compensation is generally the exclusive remedy. Jones v. Regents of University of California (2023) 97 Ca1.App.5th 502, 507 [(Jones)]. Under the premises line rule, the employment relationship generally commences once the employee enters the employer’s premises. Id. at 508. The same rule applies to determine the end of the course of employment: generally, once employment has begun, it continues, and injury is presumed to be compensable, until the employee leaves the employer’s premises. Id.

3 According to Taco Bell Franchisor, LLC, plaintiffs erroneously sued “Taco Bell Corp.”

4 “In Jones, the plaintiff Rose Jones was an employee of the Regents of the University of California. Id. at 505. Jones left at the end of her workday, exited her office suite, walked her bike a short distance and then rode her bike for about 10 seconds before she crashed and was injured. Id. at 505-06. The trial court found, and the appellate court affirmed, that her tort claims against her employer for negligence and premise liability were barred by the worker’s compensation exclusivity rule relying on the premise line rule. Id. at 511. “Here, Plaintiffs have brought causes of action for premise liability and negligence as the heirs at law and successors in-interest to ... Wrenne. The Complaint alleges that [Wrenne] was assaulted while on an uncompensated break while located on the premises of the Defendants.

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