California Labor Code Section 3600
California's Workers' Compensation Act (Lab. Code, 3600 et seq.) provides an employee's exclusive remedy against his or her employer for injuries arising out of and in the course of employment.
Specifically, Labor Code section 3600, subdivision (a), states: "Liability for the compensation provided by this division, in lieu of any other liability whatsoever to any person ... , shall, without regard to negligence, exist against an employer for any injury sustained by his or her employees arising out of and in the course of the employment ... ."
"Subject to certain statutory exceptions not applicable here, an injured employee's sole and exclusive remedy against his or her employer is the right to recover workers' compensation benefits ... ," provided the injury arose out of and in the course of employment.)
The phrase "arising out of" refers to the origin or cause of the injury, while the phrase "in the course of employment" refers to the time and place of the injury. (State Comp. Ins. Fund v. Ind. Acc. Com. (1952) 38 Cal.2d 659, 661 242 P.2d 311; Argonaut Ins. Co. v. Workmen's Comp. App. Bd. (1967) 247 Cal.App.2d 669, 676-677.)
Courts have consistently recognized the act's two-pronged requirement: the injury must have arisen out of and occurred in the course of employment. Indeed, the California Supreme Court has described this two-pronged requirement as "the cornerstone of the workers' compensation system." (Maher v. Workers' Comp. Appeals Bd. (1983) 33 Cal.3d 729, 732-733; see Vaught, supra, 157 Cal.App.4th at p. 1544.)