Carpenter v. Universal City Studios
After plaintiff Christopher Carpenter suffered serious injury to his hand while working as a grip on the set of the Universal Network Television, L.L.C. (UNT) series Dragnet, he sued defendant Universal City Studios L.L.L.P. (UCS) in tort alleging that UCS was liable as the landlord of the soundstage where he was injured. UCS raised the affirmative defense that it was Carpenters special employer under the borrowed servant doctrine, with the result that Carpenter was statutorily barred from bringing a tort action against it under the workers compensation exclusivity rule. (Lab. Code, 3602.)[1] The jury found by special verdict that UCS was Carpenters special employer. The trial court denied Carpenters motions for judgment notwithstanding the verdict (JNOV), directed verdict, and motion for new trial, and entered judgment in favor of UCS. Carpenter appeals. Court hold that the evidence supports the jurys special verdict with the result the trial court did not err in denying Carpenters three motions. Accordingly, the judgment is affirmed.



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