Up until November 2, 2020, if a trucking company admitted respondeat superior, it could not be held independently liable for negligent hiring, training, supervision, and entrustment, and was entitled to summary judgment on such claims. No longer. In Quynn v. Hulsey, the Georgia Supreme Court revived such claims against the trucking company, concluding that Georgia’s apportionment statute, O.C.G.A. § 51-12-33, abrogated the “Respondeat Superior Rule.”
The upshot: Evidence of an employer’s negligence, if any, may be admissible even where it has admitted respondeat superior.
Read the full opinion here.