Antonio v. SSA Security, Inc., No. 13-1031 (4th Cir. 2015)Annotate this Case
Appellant-homeowners were victims of one of the largest residential arsons in Maryland history. Appellants sought to hold SSA Security, Inc. responsible for the arsons, which were allegedly committed by one of SSA's security guards. The district court granted summary judgment for SSA. On appeal, the Fourth Circuit certified to the Court of Appeals of Maryland a question of law regarding the Maryland Security Guards Act. The Court of Appeals answered that the Act does not impose liability beyond common law principles of respondeat superior such that an employer may be responsible for off-duty criminal acts while he or she was on duty. Because Appellants thus could not satisfy the common law doctrine of respondeat superior, the First Circuit affirmed in full the district court’s grant of summary judgment in SSA’s favor.
This opinion or order relates to an opinion or order originally issued on April 14, 2014.