Bolden v. Tisdale et al.Annotate this Case
In September 2015, the Tampa Bay Buccaneers played the New Orleans Saints in the New Orleans Superdome. In preparation for the game, the Buccaneers’ Director of Football Security Operations contacted the New Orleans Police Department (“NOPD”) to request motorcycle escorts, by off-duty law enforcement for officers, for the team’s buses traveling in the New Orleans area, which were to include an escort after the game when the team buses would travel from the Superdome to the airport. NOPD agreed to provide the necessary off-duty officers, along with officers from the Jefferson Parish Sheriff’s Office (“JPSO”), for the Buccaneer team buses. At issue on the motion for summary judgment filed in this case was whether the Buccaneers football organization was vicariously liable, as an employer, for the alleged negligence of an off-duty Jefferson Parish sheriff’s deputy, who was part of the motorcycle escort for the team’s buses, when the motorcycle the deputy was riding collided with another deputy directing traffic on foot in an intersection. The Louisiana Supreme Court held that the unrebutted evidence presented by defendants moving for summary judgment showed there was no employee-employer relationship between the deputy sheriff and the Buccaneers under the facts and circumstances of this case; therefore, the Court reversed the denial of the Buccaneers’ motion for summary judgment and remanded to the district court for entry of a summary judgment in favor of defendants.