Schurman Family Company TIC v. Superior Court (Privette Doctrine Extended to Non-Hiring Landlord)
California's First Appellate District ruled on August 26, 2026 that a warehouse owner is protected from a contractor's employee's injury lawsuit under the Privette doctrine, even though the landlord itself never hired the contractor. The court held Privette extends to any party within the 'chain of delegation' leading to a contractor's retention, reversing a trial court that had denied summary judgment because the landlord was not the direct hiring party.
Why it matters
Widens Privette doctrine protection for California commercial landlords whose leases authorize tenants to bring in independent contractors for installation or maintenance work, narrowing a liability gap counsel previously treated as uncertain whenever the landlord itself was not the hiring party. Landlords should still confirm their leases clearly contemplate the type of contracted work at issue, since the doctrine's traditional exceptions for retained control or undisclosed hazards remain unaffected.
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