In Murk v. Aronsen the Washington Supreme Court had occasion to consider a landowner's tort liability where work is placed under the control of an independent contractor. In a 5-to-4 decision the court held that an owner is not liable to a contractor's servant injured by the negligence of a contractor who has control of the premises. By its decision the court has reaffirmed its earlier position, despite a trend toward expanding the exceptions to the rule of non-liability for torts of independent contractors.
Washington Case Law,
Torts—Landowner's Liability to Servants of Independent Contractors,
37 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol37/iss2/20