Can a plaintiff recover from injuries sustained as a result of negligent driving?

These cases are the exception. Primary assumption of the risk ordinarily does not bar employees from recovering when they are injured as a result of on-the-job risks created by third parties. Particularly outside the work of public safety officers, "[t]he duty to avoid injuring others normally extends to those engaged in hazardous work. Thus, for example, both publicly and privately employed highway workers, who face the obvious occupational hazard of working in the middle of traffic, may recover for injuries caused by a third party's negligent driving." (Neighbarger v. Irwin Industries, Inc. (1994) 8 Cal.4th 532, 536 (Neighbarger).) Even "[t]he firefighter does not assume every risk of his or her occupation. [Citation.] The rule does not apply to conduct other than that which necessitated the summoning of the firefighter or police officer, and it does not apply to independent acts of misconduct that are committed after the firefighter or police officer has arrived on the scene." (Id. at p. 538.)