March 18, 2025 | Oakland, CA — MedLegalNews.com — Workers compensation law took center stage in the recent California Court of Appeal decision involving school volunteer Catherine Kuo. On March 18, 2025, in Oakland, CA, the appellate court upheld a summary judgment favoring the Dublin Unified School District (DUSD) in a lawsuit filed by Kuo’s family after her death during a volunteer event. The court ruled that under California Labor Code section 3364.5, Kuo was considered an employee for the purpose of workers compensation benefits, making that system the exclusive remedy available to her family.
Lawsuit Alleges Negligence and Premises Liability
Kuo’s family filed a wrongful death lawsuit against the Dublin Unified School District (DUSD), alleging negligence and premises liability. The complaint claimed that the district failed to establish, communicate, and enforce adequate safety protocols during the volunteer event where the fatal accident occurred.
According to court filings, the family argued that DUSD’s lack of supervision and safety planning created hazardous conditions that directly contributed to Kuo’s death. They contended that, as a volunteer rather than a paid employee, Kuo should not have been restricted to the workers compensation system and should have been permitted to pursue civil remedies.
However, the district maintained that under California Labor Code section 3364.5, school volunteers are legally covered by workers compensation benefits, which preclude additional negligence or liability claims.
DUSD Cites Workers’ Compensation Exclusivity
In response to the lawsuit, the Dublin Unified School District (DUSD) moved for summary judgment, invoking workers compensation exclusivity as its legal defense. The district argued that under California Labor Code section 3364.5, school volunteers are deemed employees for the purpose of workers compensation benefits.
DUSD maintained that because Catherine Kuo’s tragic death occurred while she was performing approved volunteer duties, her family’s sole remedy was through the workers compensation system — not through a separate civil negligence claim.
The Alameda County Superior Court agreed with the district’s position and ruled that workers compensation was the exclusive legal recourse available for injuries or fatalities sustained by volunteers acting within the scope of their assigned activities. This decision effectively barred the plaintiffs from pursuing additional claims against the district.
Court of Appeal Affirms Summary Judgment
School Volunteer Catherine Kuo: Kuo’s family appealed the decision, but the California Court of Appeal upheld the ruling, citing that “any injury” under section 3364.5 covered fatal injuries.
The appellate court also found that a DUSD resolution acknowledging volunteers’ entitlement to workers’ compensation benefits met statutory requirements.
Plaintiffs’ Argument Rejected
The plaintiffs argued that DUSD did not treat volunteers as employees, but the court ruled that consistent implementation was not required.
Court Reaffirms Workers’ Compensation as Exclusive Remedy
Ultimately, the California Court of Appeal confirmed that workers’ compensation was the sole legal remedy for Kuo’s family.
For verified information about California’s workers compensation laws, visit the California Department of Industrial Relations (DIR).
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FAQS: Workers Compensation Exclusive Remedy
What does workers compensation exclusive remedy mean?
It means that when an injury or death occurs during covered activities, workers compensation benefits are the only legal remedy available to the injured party or their family.
Why did the court rule workers compensation was the exclusive remedy in Kuo’s case?
The court found that volunteers, under Labor Code section 3364.5, are classified as employees eligible for workers compensation coverage, making it the sole remedy.
Does the exclusive remedy rule apply to school volunteers in California?
Yes. California law allows school districts to treat volunteers as employees for workers compensation purposes if resolutions or policies are properly adopted.
Can families of volunteers file separate negligence claims after a fatal incident?
Generally, no. If workers compensation applies, it bars additional negligence or liability lawsuits against the employer or organization.