American Cargo Express v. Super Ct.

Mainstay Business Solutions (Mainstay), a division of the Blue Lake Rancheria Economic Development Corporation, was a tribal government-sponsored entity of Blue Lake Rancheria, a federally recognized Indian tribe. Mainstay operated a temporary staffing business, assigning temporary workers to its clients. It also operated an employee leasing business in which employees of Mainstay’s clients were placed on Mainstay’s payroll and leased back to the clients. The California Self-Insurers’ Security Fund (SISF) assumed the workers’ compensation obligations when Mainstay defaulted on its obligations to self-insure. SISF then sued Mainstay, Mainstay’s clients and others to recover its costs and liabilities. Among other things, the trial court granted SISF’s motion for judgment on the pleadings against Mainstay’s clients. Mainstay’s clients filed a petition for writ of mandate and/or prohibition to challenge the trial court’s order. SISF argued on appeal: (1) writ review was not appropriate because the main issue presented was rendered moot by the enactment of Labor Code section 3701.9. On the merits, Mainstay’s clients argued: (2) SISF’s claim was subject to the exclusive remedy provisions of the Workers Compensation Act and should have been brought before the Workers Compensation Appeals Board; and (3) their agreements with Mainstay in compliance with Labor Code section 3602(d) serve to bar SISF’s civil action. Finding no reversible error, the Court of Appeal affirmed. View "American Cargo Express v. Super Ct." on Justia Law