Nava v. Rivas-Del ToroAnnotate this Case
Defendant Christian Rivas-Del Toro is a Mexican citizen who was residing and working in the United States illegally. In the summer of 2005, he began working as a truck driver for co-defendants Willard, Michael, and Douglas Cranney, who are collectively called "Cranney Farms," the name under which they did business. When he began work for Cranney Farms, Defendant had a valid Mexican chauffeur license. While driving a farm truck, Defendant failed to stop at a stop sign and struck another vehicle in an intersection. He contended that the trailer brakes malfunctioned. Plaintiff Beatriz Nava was driving the other vehicle, and her minor daughter was a passenger. She filed this action seeking to recover for property damage and personal injuries to herself and her daughter. In her amended complaint, she alleged that Cranney Farms was liable because it was the registered owner of the truck and Defendant was driving with Cranney Farms’s permission and that Cranney Farms had recklessly allowed the vehicle to become unsafe to operate. Cranney Farms moved for summary judgment on the ground that pursuant to Idaho Code section 6-1607 it was not liable for the negligence of its employee because he was outside the course and scope of his employment at the time of the accident. After the motion was briefed and argued, the district court held that because Defendant chose a longer route in order to avoid law enforcement because he was in the country illegally, Plaintiffs failed to satisfy Idaho Code section 6-1607(2). It ordered that Cranney Farms was entitled to a judgment dismissing the action as to it. Plaintiffs and Defendant moved for reconsideration, which the court denied. It entered judgment dismissing the action with prejudice as to Cranney Farms, and it certified that judgment as final pursuant to Idaho Rule of Civil Procedure 54(b). Plaintiffs appealed and Defendant cross-appealed. Upon review, the Supreme Court concluded that because the burden never shifted to Plaintiffs to provide evidence regarding their claim of negligent maintenance, the district court erred in granting summary judgment on that claim. Furthermore, the Court found that the ground upon which the trial court dismissed the action against the owners (that Defendant was an employee and was outside the course and scope of his employment) was not a defense to the claims alleged in the complaint, the Court vacated the district court's judgment and remanded the case for further proceedings.