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

13 Hawaii opinions name it 2 courts 1957–2025 1 in the last five years

The cases below were cited by Hawaii 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 (8)

CaseFollowedCited
Orso v. City and County of Honolulugreen
haw · 1975 · cited in 1 Hawaii opinions naming this issue, 2025–2025
2 sentences

2025See Orso v. City & Cnty. of Honolulu, 56 Haw. 241, 248 , 534 P.2d 489, 493 (1975) (holding under the doctrine of respondeat superior that a “prosecuting attorney is an officer 22 *** FOR PUBLICATION IN WEST’S HAWAIʻI REPORTS AND PACIFIC REPORTER *** of the executive branch of the [county]”).

2025See Orso v. City & Cnty. of Honolulu, 56 Haw. 241, 248 , 534 P.2d 489, 493 (1975) (holding under the doctrine of respondeat superior that a “prosecuting attorney is an officer 22 *** FOR PUBLICATION IN WEST’S HAWAIʻI REPORTS AND PACIFIC REPORTER *** of the executive branch of the [county]”).

11
Reed v. City and County of Honolulugreen
haw · 1994 · cited in 1 Hawaii opinions naming this issue, 1995–1995
2 sentences

1995See Reed v. City and County of Honolulu, 76 Hawai`i 219, 227, 873 P.2d 98, 106 (1994); Kamanu v. E.E.

1995See Reed v. City and County of Honolulu, 76 Hawai'i 219, 227 , 873 P.2d 98, 106 (1994); Kamanu v. E.E.

11
Bruce v. Chas Roberts Air Conditioning, Inc.green
arizctapp · 1990 · cited in 1 Hawaii opinions naming this issue, 1994–1994
2 sentences

1994Regarding the issue of benefit to the employer, both the majority and dissenting opinions in Bruce apparently inferred from the record that "the employer benefitted from allowing the beer drinking because it kept employees available at the employer’s yard for performing additional work." See Bruce (Kleinschmidt, J., dissenting), 166 Ariz. at 229 n. 6, 801 P.2d at 464 n. 6 (emphasis added); see also id. at 222-23, 801 P.2d at 457 (noting, in the majority opinion, that management knew the workers remained on the premises after work to drink beer).

1994Regarding the issue of benefit to the employer, both the majority and dissenting opinions in Bruce apparently inferred from the record that "the employer benefitted from allowing the beer drinking because it kept employees available at the employer’s yard for performing additional work." See Bruce (Kleinschmidt, J., dissenting), 166 Ariz. at 229 n. 6, 801 P.2d at 464 n. 6 (emphasis added); see also id. at 222-23, 801 P.2d at 457 (noting, in the majority opinion, that management knew the workers remained on the premises after work to drink beer).

11
Varela v. Jonesgreen
ca10 · 1984 · cited in 1 Hawaii opinions naming this issue, 1986–1986
1 sentence

1986Monell v. New York City Dept. of Social Services, supra. “[I]t is liable only if its employees deprived plaintiff of [his] constitutional rights pursuant to a policy or custom of the city.” Varela v. Jones, 746 F.2d 1413, 1418 (10th Cir. 1984).

11
Johnston v. Longgreen
cal · 1947 · cited in 1 Hawaii opinions naming this issue, 1984–1984
2 sentences

1984We are aware that a justification for the respondeat superior doctrine is “the fact that the employer may spread the risk through insurance and carry the cost thereof as part of his costs of doing business.” Johnston v. Long, 30 Cal.2d 54, 64 , 181 P.2d 645, 651 (1947).

1984We are aware that a justification for the respondeat superior doctrine is “the fact that the employer may spread the risk through insurance and carry the cost thereof as part of his costs of doing business.” Johnston v. Long, 30 Cal.2d 54, 64 , 181 P.2d 645, 651 (1947).

11
Hulsman v. Hemmeter Development Corp.green
haw · 1982 · cited in 1 Hawaii opinions naming this issue, 1984–1984
2 sentences

1984Under this doctrine, “the employer is held accountable and liable for the negligent acts of its employees.” Hulsman v. Hemmeter Development Corp., 65 Haw. at 61, 647 P.2d at 717 .

1984Under this doctrine, “the employer is held accountable and liable for the negligent acts of its employees.” Hulsman v. Hemmeter Development Corp., 65 Haw. at 61, 647 P.2d at 717 .

11
Brinkman v. City of Indianapolisgreen
indctapp · 1967 · cited in 1 Hawaii opinions naming this issue, 1975–1975
2 sentences

1975See Brinkman v. City of Indianapolis, 141 Ind. App. 662, 669 , 231 N.E.2d 169, 173 (1967); City of Lexington v. Yank, Ky., 431 S.W.2d 892 (1968).

1975See Brinkman v. City of Indianapolis, 141 Ind. App. 662, 669 , 231 N.E.2d 169, 173 (1967); City of Lexington v. Yank, Ky., 431 S.W.2d 892 (1968).

11
Fisher v. State of New Yorkgreen
ny · 1961 · cited in 1 Hawaii opinions naming this issue, 1973–1973
2 sentences

1973See Fisher v. State, 10 N.Y.2d 60 , 176 N.E.2d 72 , 217 N.Y.S.2d 52 (1961).

1973See Fisher v. State, 10 N.Y.2d 60 , 176 N.E.2d 72 , 217 N.Y.S.2d 52 (1961).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (14)

CaseCitedYears
Kang v. Charles Pankow Associates green
hawapp · 1984
2 sentences

1994Foreseeability in this context is consistent with the underlying justification for the respondeat superior doctrine, which is “the fact that the employer may spread the risk through insurance and carry the cost thereof as part of his costs of doing business.” Kang, 5 Haw.App. at 10 , 675 P.2d at 809 . 11 .

1994Foreseeability in this context is consistent with the underlying justification for the respondeat superior doctrine, which is “the fact that the employer may spread the risk through insurance and carry the cost thereof as part of his costs of doing business.” Kang, 5 Haw.App. at 10 , 675 P.2d at 809 . 11 .

21991–1994
Henderson v. Professional Coatings Corp. green
haw · 1991
2 sentences

1994With respect to the respondeat superior claim, the court held that the enterprise theory did not apply because “the acts involved ... did not occur within authorized work hours and were not actuated, even in part, by a purpose to serve [the] employer.” Id. at 394 , 819 P.2d at 89 .

1994With respect to the respondeat superior claim, the court held that the enterprise theory did not apply because “the acts involved ... did not occur within authorized work hours and were not actuated, even in part, by a purpose to serve [the] employer.” Id. at 394 , 819 P.2d at 89 .

21994–1994
Doe v. Durtschi green
idaho · 1986
2 sentences

2002However, we also agree, where "the government entity should have reasonably anticipated that one of [its] employees would commit an intentional tort," Durtschi, 716 P.2d at 1245 , that the STLA's intentional tort exception does not insulate the governmental entity from liability.

2002However, we also agree, where “the government entity should have reasonably anticipated that one of [its] employees would commit an intentional tort,” Durtschi, 716 P.2d at 1245 , that the STLA’s intentional tort exception does not insulate the governmental entity from liability.

12002–2002
Bennett v. United States green
ca9 · 1986
2 sentences

2002Id. at 1503-04 .

2002Id. at 1503-04 .

12002–2002
United States v. Shearer green
scotus · 1985
2 sentences

2002We agree, insofar as such a claim is, in essence, little else than a "semantical recasting," Shearer, 473 U.S. at 55 , 105 S.Ct. 3039 , which attempts to cloak a respondeat superior claim in negligence clothing so as to circumvent the intentional tort exception.

2002We agree, insofar as such a claim is, in essence, little else than a "semantical recasting," Shearer, 473 U.S. at 55 , 105 S.Ct. 3039 , which attempts to cloak a respondeat superior claim in negligence clothing so as to circumvent the intentional tort exception.

12002–2002
Dickinson v. Edwards green
wash · 1986
2 sentences

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

11994–1994
John Boyd Chastain, Jr., Administrator of the Estate of Marilyn Gail Chastain, Deceased v. Litton Systems, Inc. green
ca4 · 1983
2 sentences

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

11994–1994
Chesterman v. Barmon green
or · 1988
2 sentences

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

1994In so holding, we adopt the relevant reasoning of the United States Court of Appeals for the Fourth Circuit in Chastain v. Litton Systems, Inc., 694 F.2d 957 (4th Cir.1982), the Oregon Supreme Court in Chesterman v. Barmon, 305 Or. 439 , 753 P.2d 404 (1988), and the Washington Supreme Court’s analysis of the issue in Dickinson v. Edwards, 105 Wash.2d 457 , 716 P.2d 814 (1986). 6 In Chastain , the court discussed the re-spondeat superior analysis in two parts: the negligent act, and whether that act was undertaken within the scope of employment. “[W]e believe [becoming intoxicated] is the criti

11994–1994
Harris v. Trojan Fireworks Co. green
calctapp · 1981
2 sentences

1984Appellants contend that (1) other jurisdictions apply the rationale used in determining whether an injury arose “out of and in the course of employment” in workers’ compensation cases to the resolution of “scope of employment” issues under the respondeat superior doctrine in tort cases, Harris v. Trojan Fireworks Co., 120 Cal. App.3d 157 , 174 Cal. Rptr. 452 (1981); Rodgers v. Kemper Construction Co., 50 Cal. App.3d 608 , 124 Cal. Rptr. 143 (1975); (2) the workers’ compensation administrative decisions in Hawaii hold that traveling employees are continuously within the scope of employment whil

1984Appellants contend that (1) other jurisdictions apply the rationale used in determining whether an injury arose “out of and in the course of employment” in workers’ compensation cases to the resolution of “scope of employment” issues under the respondeat superior doctrine in tort cases, Harris v. Trojan Fireworks Co., 120 Cal. App.3d 157 , 174 Cal. Rptr. 452 (1981); Rodgers v. Kemper Construction Co., 50 Cal. App.3d 608 , 124 Cal. Rptr. 143 (1975); (2) the workers’ compensation administrative decisions in Hawaii hold that traveling employees are continuously within the scope of employment whil

11984–1984
Rodgers v. Kemper Construction Co. green
calctapp · 1975
2 sentences

1984Appellants contend that (1) other jurisdictions apply the rationale used in determining whether an injury arose “out of and in the course of employment” in workers’ compensation cases to the resolution of “scope of employment” issues under the respondeat superior doctrine in tort cases, Harris v. Trojan Fireworks Co., 120 Cal. App.3d 157 , 174 Cal. Rptr. 452 (1981); Rodgers v. Kemper Construction Co., 50 Cal. App.3d 608 , 124 Cal. Rptr. 143 (1975); (2) the workers’ compensation administrative decisions in Hawaii hold that traveling employees are continuously within the scope of employment whil

1984Appellants contend that (1) other jurisdictions apply the rationale used in determining whether an injury arose “out of and in the course of employment” in workers’ compensation cases to the resolution of “scope of employment” issues under the respondeat superior doctrine in tort cases, Harris v. Trojan Fireworks Co., 120 Cal. App.3d 157 , 174 Cal. Rptr. 452 (1981); Rodgers v. Kemper Construction Co., 50 Cal. App.3d 608 , 124 Cal. Rptr. 143 (1975); (2) the workers’ compensation administrative decisions in Hawaii hold that traveling employees are continuously within the scope of employment whil

11984–1984
Nakagawa v. Apana green
haw · 1970
2 sentences

1981And, significantly, there was no showing that an employment relationship had been established with the knowing consent of the employee. 3 • The lending employer in Kepa also asserted it should not be liable for compensation under principles enunciated in Nakagawa v. Apana, 52 Haw. 379 , 477 P.2d 611 (1970), a negligence action where a lending employer’s vicarious tort liability was determined in accord with common law principles governing master-servant relationships and the doctrine of respondeat superior.

1981And, significantly, there was no showing that an employment relationship had been established with the knowing consent of the employee. 3 • The lending employer in Kepa also asserted it should not be liable for compensation under principles enunciated in Nakagawa v. Apana, 52 Haw. 379 , 477 P.2d 611 (1970), a negligence action where a lending employer’s vicarious tort liability was determined in accord with common law principles governing master-servant relationships and the doctrine of respondeat superior.

11981–1981
Lucas v. Liggett & Myers Tobacco Co. green
haw · 1968
2 sentences

1980On the contrary, the modern trend has been towards a liberalizing of the “scope of employment” and a corresponding enlargement of employer’s tort liability even to situations where the employee has committed theft of company inventory, Lucas v. Liggett & Myers Tobacco Co., 50 Haw. 477 , 442 P.2d 460 (1968), or has been drinking heavily.

1980On the contrary, the modern trend has been towards a liberalizing of the “scope of employment” and a corresponding enlargement of employer’s tort liability even to situations where the employee has committed theft of company inventory, Lucas v. Liggett & Myers Tobacco Co., 50 Haw. 477 , 442 P.2d 460 (1968), or has been drinking heavily.

11980–1980
City of Lexington v. Yank green
kyctapphigh · 1968
1 sentence

1975See Brinkman v. City of Indianapolis, 141 Ind. App. 662, 669 , 231 N.E.2d 169, 173 (1967); City of Lexington v. Yank, Ky., 431 S.W.2d 892 (1968).

11975–1975
Bailey's Bakery v. Tax Commissioner green
haw · 1948
1 sentence

1957(Ross v. Cummins, 7 Ill. [2d] 595, 131 N. E. [2d] 521) This court stated in Bailey^s Bakery v. Tax Commissioner, supra, at page 32, “But in our opinion, due to the original sphere of application of the control test to the vicarious liability under the doctrine of respondeat superior, the rigidity of the test must yield to the objects and purposes of social insurance and the control reserved to the principal for unemployment compensation purposes need not extend to all the details of the physical performance of the service by the worker that may be essential to the master-servant relationship b

11957–1957

Statutes the citing opinions construe

HI § Haw. Rev. Stat. § 662-15 (3) HI § Haw. Rev. Stat. § 662-2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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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