How have courts interpreted section 3601(a)(1)(2)(3) of the California Industrial Accident Prevention Act?

In reaching its conclusion, the Vellis court observed that section 3601 as amended "is a recognition that industrial accidents are a matter of enterprise liability" and stated: "This section eliminates the former rights of an employer for subrogation against a negligent employee causing injuries. It also eliminates actions by the employee against a co-employee except in the specific instances provided in section 3601(, subdivision) (a)(1)(2)(3). Exceptions to the plain wording of the statute should clearly be indicated in either the pleadings or declarations. To rule otherwise would place the risk of loss on fellow employees contrary to the intent of the statute." (Vellis v. Albertson, supra, 267 Cal.App.2d 285, 291, 72 Cal.Rptr. 841, 846.)