Chapman v. Black
In Chapman v. Black, 49 Wash. App. 94, 741 P.2d 998 (Wash. Ct. App. 1987), an employee of an independent contractor sued homeowners for injuries sustained when he fell from the roof of a house being constructed for homeowners.
The employee sought to impose liability on the homeowners for negligently hiring the independent contractor for whom the employee worked. The Washington Court of Appeals refused to find that the homeowners owed the employee "a duty to protect him from the negligence of his own employer." Id. at 1004.
"'The general rule is that the owner of premises owes to the servant of the independent contractor employed to perform work on his premises the duty to avoid endangering him by his own negligence or affirmative act, but owes no duty to protect him from the negligence of his own master." Id.