In 1962, the California Supreme Court held, in Woolen, that, under the doctrine of peculiar risk, an employee of an independent contractor protected by Workers Compensation could maintain, for a job-related injury, a tort action against the landowner or general contractor who employed the independent contractor. In 1993, in Privette, the Court overruled its holding in Woolen. Since then, several Court of Appeal and Supreme Court decisions have determined the extent of Privette's application. The following citations are relevant to this question: