Hailliburton Energy Servs. Inc. v. Dept of Transp.

Where an employee was responsible for a vehicular accident while driving a company truck outside of the scope of his employment and for personal reasons, an employer cannot be held liable for such conduct under the doctrine of respondeat superior.

Plaintiffs sued the employer defendant for personal injuries and damages resulting from a car accident involving one of employer’s employees, whom at the time, was driving the employer’s truck and was using the company vehicle to drive over fifty miles to another location to purchase another car for his family. At no time did the employee inform the employer of his use of the vehicle for such purpose nor did the employer given the employee permission to use such truck for personal reasons, as was the case herein.

The plaintiffs asserted their claims under the doctrine of respondeat superior, where the employer should be held liable for the negligence acts of its employees, especially in this case, where the plaintiffs argued that the employee was driving the employer’s vehicle and engaged in negligent conduct which became the basis for such claims. The trial court dismissed plaintiffs’ claims on the basis that such employee conduct fell outside the scope of the employment relationship, to which the employer could not be held liable.

The Court of Appeals

The California Court of Appeals affirmed, reasoning as did the trial court, that the the doctrine of respondeat superior, only imposes liability and applies to situations where the employee is acting negligently in the course of the employment relationship or on behalf of the employer. Specifically, the California Court of Appeals described that an employer’s responsibility only attaches in circumstances where any injuries sustained and allegedly caused by employee, occur during the ordinary course of business.

The Court was specific to point out that liability and responsibility can still attach where an employee even slightly deviates from normal duties, if the deviation and resulting harm thereof, is foreseeable. Here, the Court determined that it was not remotely foreseeable by the employer, that the employee at issue would actually use the company truck for personal reasons that fell outside the scope of employment and the ordinary course of business, and in fact, the employer in this case, had no actual or constructive knowledge of such events or authorized such use of the company vehicle.

Employment based claims involving a large employer requires a law firm that is experienced, competent, and knowledgeable concerning the complexities of employment injury claims and the recovery of attorney fees. If you have any employment-related injury claims and are considering contact the Orange County Employment Lawyers at Nassiri Law Group, practicing in Orange County, Riverside, and Los Angeles. Call 714-937-2020.