respondeat superior doctrine (Kentucky) · Go Syfert
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respondeat superior doctrine in Kentucky

27 Kentucky opinions name it 3 courts 1928–2025 5 in the last five years

The cases below were cited by Kentucky courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Patterson v. Blairgreen
ky · 2005 · cited in 3 Kentucky opinions naming this issue, 2024–2025
2 sentences

2025“Vicarious liability, sometimes referred to as the doctrine of respondeat superior, is not predicated upon a tortious act of the employer but upon the imputation to the employer of a tortious act of the employee[.]” Patterson v. Blair, 172 S.W.3d 361, 369 (Ky. 2005) (citation omitted).

2024Patterson v. Blair, 172 S.W.3d 361, 363 (Ky. 2005).

33
Johnson v. Brewergreen
kyctapphigh · 1936 · cited in 2 Kentucky opinions naming this issue, 2002–2024
2 sentences

2002Vicarious liability, sometimes referred to as the doctrine of respondeat superior, is not predicated upon a tortious act of the employer but upon the imputation to the employer of a tortious act of the employee "by considerations of public policy and the necessity for holding a responsible person liable for the acts done by others in the prosecution of his business, as well as for placing on employers an incentive to hire only careful employees." Johnson v. Brewer, 266 Ky. 314 , 98 S.W.2d 889, 891 (1936).

2002Vicarious liability, sometimes referred to as the doctrine of respondeat superior, is not predicated upon a tortious act of the employer but upon the imputation to the employer of a tortious act of the employee "by considerations of public policy and the necessity for holding a responsible person liable for the acts done by others in the prosecution of his business, as well as for placing on employers an incentive to hire only careful employees." Johnson v. Brewer, 266 Ky. 314 , 98 S.W.2d 889, 891 (1936).

22
Disabled American Veterans, Department of Kentucky, Inc. v. Crabbgreen
kyctapp · 2005 · cited in 2 Kentucky opinions naming this issue, 2024–2024
2 sentences

2024Disabled American Veterans, Dep’t of Kentucky, Inc. v. Crabb, 182 S.W.3d 541, 555 (Ky. App. 2005) (internal quotation marks and footnote omitted). “[A]n employer’s liability is limited only to those employee actions committed in the scope of employment.” Patterson v. Blair, 172 S.W.3d 361, 366 (Ky. 2005).

2024Veterans, Dep’t of Kentucky, Inc. v. Crabb, 182 S.W.3d 541, 555 (Ky. App. 2005) (quoting American General Life & Accident Insurance Co. v. Hall, 74 S.W.3d 688, 692 (Ky. 2002) and Johnson v. Brewer, 266 Ky. 314 , 98 S.W.2d 889, 891 (1936)).

22
Kiser v. Neumann Company Contractors, Inc.green
kyctapphigh · 1967 · cited in 1 Kentucky opinions naming this issue, 2025–2025
1 sentence

2025However, “[i]n circumstances under which the liability of the employer is purely derivative, he cannot be held liable while the employee at the same time is found not.” Kiser v. Neumann Co. Contractors, Inc., 426 S.W.2d 935, 937 (Ky. 1967).

11
American General Life & Accident Insurance Co. v. Hallgreen
ky · 2002 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024Veterans, Dep’t of Kentucky, Inc. v. Crabb, 182 S.W.3d 541, 555 (Ky. App. 2005) (quoting American General Life & Accident Insurance Co. v. Hall, 74 S.W.3d 688, 692 (Ky. 2002) and Johnson v. Brewer, 266 Ky. 314 , 98 S.W.2d 889, 891 (1936)).

11
Taylor v. Jewish Hospital & St. Mary's Healthcare, Inc.green
kywd · 2014 · cited in 1 Kentucky opinions naming this issue, 2021–2021
1 sentence

2021Mary’s Healthcare, Inc., 26 F. Supp. 3d 642, 648 (W.D.

11
Saint Joseph Healthcare, Inc. v. Thomasgreen
· 2016 · cited in 1 Kentucky opinions naming this issue, 2021–2021
1 sentence

2021In 2016, the Supreme Court said, “Under the common law doctrine of respondeat superior, ‘a principal is vicariously liable for damages caused by torts of . . . an agent or subagent, other than an independent contractor, acting on behalf of and pursuant to the authority of the principal.’” Saint Joseph Healthcare, Inc. v. Thomas, 487 S.W.3d 864, 876 (Ky. 2016) (Supreme Court’s emphasis) (quoting Taylor v. Jewish Hosp. & St.

11
Horne v. Hallgreen
kyctapp · 1951 · cited in 1 Kentucky opinions naming this issue, 2017–2017
1 sentence

2017“The test as to the liability of the master is whether the servant was guilty of negligence in the doing of his master’s work and whether the master had the right or power to control the servant in the performance of the act which caused the injury.” Horne v. Hall, 246 S.W.2d 441, 443 (Ky. 1951).

11
Smith ex rel. Smith v. Smithgreen
kyctapp · 1960 · cited in 1 Kentucky opinions naming this issue, 2008–2008
2 sentences

2008The rule of respondeat superior embodies the theory that where one acts through the agency of another, in legal contemplation, he is himself acting and thus is responsible for acts of his agent. "[W]hen an agent fails in any duty which he owes to a third party or the public generally, the principal is responsible for the failure." Smith v. Smith, 333 S.W.2d 503, 504 (Ky.1960).

2008The rule of respondeat superior embodies the theory that where one acts through the agency of another, in legal contemplation, he is himself acting and thus is responsible for acts of his agent. "[When an agent fails in any duty which he owes to a third party or the public generally, the principal is responsible for the failure." Smith v. Smith, 333 S.W.2d 503, 504 (Ky.1960).

11
State Ex Rel. City Motor Co. v. District Court of the Eighth Judicial District Ex Rel. County of Cascadegreen
mont · 1975 · cited in 1 Kentucky opinions naming this issue, 2007–2007
1 sentence

2007Id. at 489.

11
Sharp v. Faulknergreen
kyctapphigh · 1942 · cited in 1 Kentucky opinions naming this issue, 2007–2007
2 sentences

2007As was noted in Sharp v. Faulkner, 292 Ky. 179 , 166 S.W.2d 62, 63 (1942), the respondeat superior doctrine has no application when an employee engages on a “personal and private trip” which has “no connection with his masters’ business.” In Weldon v. Federal Chemical Company, 378 S.W.2d 633 (Ky.1964), the sales manager of the defendant company was on his way to pick up his son at a party when he had to abandon a company vehicle on the road due to a frozen carburetor.

2007As was noted in Sharp v. Faulkner, 292 Ky. 179 , 166 S.W.2d 62, 63 (1942), the respondeat superior doctrine has no application when an employee engages on a “personal and private trip” which has “no connection with his masters’ business.” In Weldon v. Federal Chemical Company, 378 S.W.2d 633 (Ky.1964), the sales manager of the defendant company was on his way to pick up his son at a party when he had to abandon a company vehicle on the road due to a frozen carburetor.

11
Central Truckaway System, Inc. v. Mooregreen
kyctapphigh · 1947 · cited in 1 Kentucky opinions naming this issue, 1998–1998
1 sentence

1998In affirming the verdict in favor of the plaintiff, the Court held (1) that Derrett was acting in the scope of his employment, and (2) that Central Truckaway was not entitled to the defense that it used ordinary care in hiring Derrett, as such it “is not a defense where liability to a third person is predicated upon negligence of a servant under the doctrine of respondeat superior.” Id. at 728.

11
Bowen v. Gradison Construction Companygreen
kyctapphigh · 1930 · cited in 1 Kentucky opinions naming this issue, 1953–1953
2 sentences

1953See Bowen v. Gradison Construction Company, 236 Ky. 270 , 32 S.W.2d 1014 .

1953See Bowen v. Gradison Construction Company, 236 Ky. 270 , 32 S.W.2d 1014 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (28)

CaseCitedYears
Brady v. B. and B. Ice Company green
kyctapphigh · 1931
2 sentences

1953Ice Co., 242 Ky. 138 , 45 S.W.2d 1051, 1053 , the Court said: "If an owner lends his automobile to another under circumstances that do not warrant the application of the doctrine of respondeat superior, any liability attaching to him does so by reason of his own negligence in knowingly permitting the use of it in such a way as would probably cause injury to others.

1953Ice Co., 242 Ky. 138 , 45 S.W.2d 1051, 1053 , the Court said: "If an owner lends his automobile to another under circumstances that do not warrant the application of the doctrine of respondeat superior, any liability attaching to him does so by reason of his own negligence in knowingly permitting the use of it in such a way as would probably cause injury to others.

21934–1953
Keck's Administrator v. Louisville Gas & Electric Co. neutral
kyctapp · 1918
2 sentences

1934Keck’s Adm’r v. Louisville Gas & Electric Co., 179 Ky. 314 , 200 S. W. 452 , L.

1934Keck’s Adm’r v. Louisville Gas & Electric Co., 179 Ky. 314 , 200 S. W. 452 , L.

21931–1934
Weldon v. Federal Chemical Co. green
kyctapp · 1964
1 sentence

2007As was noted in Sharp v. Faulkner, 292 Ky. 179 , 166 S.W.2d 62, 63 (1942), the respondeat superior doctrine has no application when an employee engages on a “personal and private trip” which has “no connection with his masters’ business.” In Weldon v. Federal Chemical Company, 378 S.W.2d 633 (Ky.1964), the sales manager of the defendant company was on his way to pick up his son at a party when he had to abandon a company vehicle on the road due to a frozen carburetor.

12007–2007
Smith's Adm'r v. Corder neutral
kyctapp · 1956
1 sentence

1998Id. at 514 .

11998–1998
Craddock v. Imperial Casualty & Indemnity Co. green
kyctapp · 1970
1 sentence

1970A phase of this problem was considered in Craddock v. Imperial Casualty and Indemnity Company, Ky., 451 S.W.2d 658 (1970).

11970–1970
Caudill v. Pinsion, Mayor green
kyctapphigh · 1930
2 sentences

1968The basis for the opinion in Caudill v. Pinsion, 233 Ky. 12 , 24 S.W.2d 938 , is not readily discernible.

1968The basis for the opinion in Caudill v. Pinsion, 233 Ky. 12 , 24 S.W.2d 938 , is not readily discernible.

11968–1968
Hughes v. City of Duluth neutral
minn · 1938
2 sentences

1968All that the County and City did was to furnish the rights-of-way pursuant to an agreement between them that when the road was completed the City would convey to the County the rights-of-way secured by the City.” In denying liability we said: “Under the facts stated it is as once apparent that liability cannot be predicated upon the doctrine of respondeat superior, Hughes v. City of Duluth, 204 Minn. 1 , 281 N.W. 871 , 120 A.L.R. 1144 (1938), held that a city could properly be found to have had control over the work being done by W.

1968All that the County and City did was to furnish the rights-of-way pursuant to an agreement between them that when the road was completed the City would convey to the County the rights-of-way secured by the City.” In denying liability we said: “Under the facts stated it is as once apparent that liability cannot be predicated upon the doctrine of respondeat superior, Hughes v. City of Duluth, 204 Minn. 1 , 281 N.W. 871 , 120 A.L.R. 1144 (1938), held that a city could properly be found to have had control over the work being done by W.

11968–1968
Blue Valley Creamery Co. v. Cronimus green
kyctapphigh · 1937
2 sentences

1961Blue Valley Creamery Co. v. Cronimus, 270 Ky. 496 , 110 S.W.2d 286 , and Overstreet v. Thomas, Ky., 239 S.W.2d 939 , relied on by appellant, are not applicable since there was privity under the doctrine of respondeat superior.

1961Blue Valley Creamery Co. v. Cronimus, 270 Ky. 496 , 110 S.W.2d 286 , and Overstreet v. Thomas, Ky., 239 S.W.2d 939 , relied on by appellant, are not applicable since there was privity under the doctrine of respondeat superior.

11961–1961
Overstreet v. Thomas neutral
kyctapphigh · 1951
1 sentence

1961Blue Valley Creamery Co. v. Cronimus, 270 Ky. 496 , 110 S.W.2d 286 , and Overstreet v. Thomas, Ky., 239 S.W.2d 939 , relied on by appellant, are not applicable since there was privity under the doctrine of respondeat superior.

11961–1961
Higgans v. Deskins green
kyctapphigh · 1953
1 sentence

1954Higgans v. Deskins, Ky., 263 S.W.2d 108 .

11954–1954
Webb v. Dixie-Ohio Express Co., Inc. green
kyctapphigh · 1942
2 sentences

1953Webb v. Dixie-Ohio Express Co., 291 Ky. 692 , 165 S.W.2d 539 .

1953Webb v. Dixie-Ohio Express Co., 291 Ky. 692 , 165 S.W.2d 539 .

11953–1953
Hodge Drive-It-Yourself Co. v. Cincinnati green
scotus · 1932
2 sentences

1949In the course of its opinion the Supreme Court said: “There is nothing on the face of the ordinance or in the evidence or findings below to warrant the conclusion that the classification, sec. 65-1 b, is capricious, arbitrary, or so lacking in foundation as to contravene the equal protection clause.” Hodge Drive-It-Yourself Company v. City of Cincinnati, 284 U. S. 335 , 52 S. Ct. 144, 145 , 76 L.

1949In the course of its opinion the Supreme Court said: “There is nothing on the face of the ordinance or in the evidence or findings below to warrant the conclusion that the classification, sec. 65-1 b, is capricious, arbitrary, or so lacking in foundation as to contravene the equal protection clause.” Hodge Drive-It-Yourself Company v. City of Cincinnati, 284 U. S. 335 , 52 S. Ct. 144, 145 , 76 L.

11949–1949
Sherwood v. Huber & Huber Motor Exp. Co. green
kyctapphigh · 1941
2 sentences

1943Illinois Central Railroad Co. v. Appelgate’s Adm’x, 268 Ky. 458 , 105 S. W. (2d) 153 ; Sherwood v. Huber & Huber Motor Express Co., 286 Ky. 775 , 151 S. W. (2d) 1007 , 135 A. L.

1943Illinois Central Railroad Co. v. Appelgate’s Adm’x, 268 Ky. 458 , 105 S. W. (2d) 153 ; Sherwood v. Huber & Huber Motor Express Co., 286 Ky. 775 , 151 S. W. (2d) 1007 , 135 A. L.

11943–1943
Louisville N. R. Co. v. Farney green
kyctapphigh · 1943
1 sentence

1943Co. v. Farney, 295 Ky. 8 , 172 S. W;(2d) 656, we overruled the theretofore holdings of this court, that the master was liable for the negligence of his servant while engaged in the prosecution of the former’s business, notwithstanding it might be found by the jury that the servant was not negligent, even in cases where the liability of the master was based exclusively upon the negligence of the servant and liability was sought to be fastened on the master only under the doctrine of respondeat superior.

11943–1943
Illinois Cent. R. Co. v. Applegate's Adm'x green
kyctapphigh · 1936
2 sentences

1943Illinois Central Railroad Co. v. Appelgate’s Adm’x, 268 Ky. 458 , 105 S. W. (2d) 153 ; Sherwood v. Huber & Huber Motor Express Co., 286 Ky. 775 , 151 S. W. (2d) 1007 , 135 A. L.

1943Illinois Central Railroad Co. v. Appelgate’s Adm’x, 268 Ky. 458 , 105 S. W. (2d) 153 ; Sherwood v. Huber & Huber Motor Express Co., 286 Ky. 775 , 151 S. W. (2d) 1007 , 135 A. L.

11943–1943
Packard-Louisville Motor Co. v. O'Neal green
kyctapphigh · 1933
1 sentence

1942Under such a state of facts the master is not liable and the respondeat superior doctrine has no application, Wyatt v. Hodson, 210 Ky. 47 , 275 S. W. 15 ; Wells v. Combs, 251 Ky. 479 , 65 S. W. (2d) 468 ; Packard-Louisville Motor Co. v. O’Neal, 248 Ky. *183 438, 58 S. W. (2d) 630 ; Corbin Fruit Co. v. Decker, 252 Ky. 766 , 68 S. W. (2d) 434 .

11942–1942
Wells v. Combs neutral
kyctapphigh · 1933
11942–1942
Wyatt v. Hodson neutral
kyctapphigh · 1925
11942–1942
Corbin Fruit Company v. Decker neutral
kyctapphigh · 1934
2 sentences

1942Under such a state of facts the master is not liable and the respondeat superior doctrine has no application, Wyatt v. Hodson, 210 Ky. 47 , 275 S. W. 15 ; Wells v. Combs, 251 Ky. 479 , 65 S. W. (2d) 468 ; Packard-Louisville Motor Co. v. O’Neal, 248 Ky. *183 438, 58 S. W. (2d) 630 ; Corbin Fruit Co. v. Decker, 252 Ky. 766 , 68 S. W. (2d) 434 .

1942Under such a state of facts the master is not liable and the respondeat superior doctrine has no application, Wyatt v. Hodson, 210 Ky. 47 , 275 S. W. 15 ; Wells v. Combs, 251 Ky. 479 , 65 S. W. (2d) 468 ; Packard-Louisville Motor Co. v. O’Neal, 248 Ky. *183 438, 58 S. W. (2d) 630 ; Corbin Fruit Co. v. Decker, 252 Ky. 766 , 68 S. W. (2d) 434 .

11942–1942
Gaines' Administratrix v. City of Bowling Green neutral
kyctapphigh · 1930
11932–1932
City of Owensboro v. Knox's Admr. neutral
kyctapp · 1903
11932–1932
City of Harrodsburg v. Sallee neutral
kyctapp · 1911
11932–1932
City of Louisville v. Hans neutral
kyctapp · 1915
11932–1932
Gatewood v. City of Frankfort neutral
kyctapp · 1916
11932–1932
Flutmus v. City of Newport neutral
kyctapp · 1917
11932–1932
City of Mayfield v. Phipps green
kyctapp · 1924
11932–1932
Mullen & Haynes Co. v. Crisp neutral
kyctapp · 1925
11931–1931
Hill v. Poindexter green
kyctapp · 1916
11928–1928

Where else courts name it

NY 391 (1876–2026) CA 298 (1889–2026) IL 245 (1866–2025) OH 215 (1883–2026) TX 184 (1876–2026) GA 165 (1928–2026) NC 119 (1902–2026) FL 105 (1920–2026) AL 104 (1914–2025) LA 96 (1927–2025) MO 92 (1874–2025) IN 87 (1864–2026) MI 81 (1911–2026) NJ 71 (1884–2026) VA 66 (1914–2025) CT 65 (1988–2026) WA 65 (1902–2026) AZ 65 (1938–2026) TN 61 (1924–2021) MD 52 (1934–2024) PA 46 (1891–2025) MA 44 (1920–2024) OR 42 (1902–2017) WI 42 (1922–2026) NM 39 (1939–2026) MN 38 (1897–2014) OK 37 (1912–2020) CO 37 (1928–2021) MS 34 (1884–2025) WV 32 (1898–2025) KS 30 (1909–2026) UT 30 (1926–2026) NE 28 (1912–2025) KY 27 (1928–2025) IA 25 (1903–2026) DC 24 (1945–2023) SC 20 (1923–2026) VT 18 (1890–2025) ID 16 (1962–2022) AR 16 (1906–2025) MT 14 (1932–2024) HI 13 (1957–2025) ND 12 (1935–2018) SD 12 (1932–2021) DE 11 (1951–2023) NH 11 (1985–2023) NV 9 (1978–2014) WY 9 (1980–2020) ME 8 (1923–2021) RI 8 (1949–2006) AK 7 (1971–2023) VI 4 (1998–2016)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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