Laurence v. Salt River Project Agricultural Improvement & Power District
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The Supreme Court overruled in substantial part DeGraff v. Smith, 62 Ariz. 261 (1945), which concluded that dismissing a claim against an employee with prejudice serves to exonerate that employee from negligence and thus simultaneously adjudicates a respondent superior claim against the employer, holding that if a tort claim against the employee was dismissed for reasons unrelated to its merits, the respondent superior claim remains viable.
Jacob Laurence and his son were injured when a truck owned by Salt River Project Agricultural Improvement & Power District (SRP) and driven by John Gabrielson, SRP's employee, collided with Laurence's vehicle. Laurence brought this action claiming that SRP was vicariously liable for Gabrielson's negligence. The superior court granted Gabrielson's motion for summary judgment as it pertained to Laurence's claim due to untimeliness but denied the motion as it pertained to the minor son's claim. The court then granted SRP's motion for summary judgment on Laurence's respondeat superior claim because the court had granted summary judgment for Gabrielson on that claim. The court ultimately dismissed all claims, and the court of appeals affirmed. The Supreme Court vacated and reversed, holding (1) DeGraff was based on incorrect reasoning; and (2) therefore, the superior court erred in entering summary judgment for SRP.
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