Sandoval v. Qualcomm Incorporated

Summary

The court held that Qualcomm owed no tort duty to the employee of its independent contractor because Qualcomm had delegated control of the worksite, disclosed the relevant electrical hazards, and did not affirmatively contribute to the injury through retained control. The court clarified that a retained-control claim requires control over the manner of performing entrusted work, actual exercise of that control, and affirmative contribution to the injury. It also held that the jury instruction used below inadequately stated those requirements, reversed the Court of Appeal, and directed entry of judgment for Qualcomm notwithstanding the verdict.