Peredia v. HR Mobile Servs., Inc.

*160*683This appeal addresses the circumstances under which a safety consultant retained by a California employer owes a duty of care to the employer's workers. California recognizes the common law theory of negligent undertaking, which is described in section 324A of the Restatement Second of Torts (section 324A). Our Supreme Court set forth the five elements of a negligent undertaking cause of action in *684Artiglio v. Corning Inc. (1998) 18 Cal.4th 604, 76 Cal.Rptr.2d 479, 957 P.2d 1313 ( Artiglio ), three of which are related to the duty of care. Our Supreme Court has not applied these elements…