respondeat superior doctrine (Rhode Island) · Go Syfert
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respondeat superior doctrine in Rhode Island

8 Rhode Island opinions name it 2 courts 1949–2006 0 in the last five years

The cases below were cited by Rhode Island 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 (4)

CaseFollowedCited
Di Cosala v. Kaygreen
nj · 1982 · cited in 2 Rhode Island opinions naming this issue, 1984–1992
2 sentences

1984Therefore the scope of employment limitation on liability which is a part of the respondeat superior doctrine is not implicit in the wrong of negligent hiring.” Id. 91 N.J. at 172-73 , 450 A.2d at 515 .

1984Therefore the scope of employment limitation on liability which is a part of the respondeat superior doctrine is not implicit in the wrong of negligent hiring.” Id. 91 N.J. at 172-73 , 450 A.2d at 515 .

12
Russian v. Life-Cap Tire Services, Inc.green
ri · 1992 · cited in 1 Rhode Island opinions naming this issue, 1997–1997
1 sentence

1997See, Mainella, 608 A.2d 1145 (liability of an employer for negligent supervision or hiring arises out of "a totally different occurrence" from the liability of an employer under the doctrine of respondeat superior.) Therefore, the "identity-of-transaction test" is satisfied.

11
Welsh Manufacturing, Division of Textron, Inc. v. Pinkerton's, Inc.green
ri · 1984 · cited in 1 Rhode Island opinions naming this issue, 1992–1992
1 sentence

1992See Welsh Manufacturing, 474 A.2d at 440 (quoting DiCosala v. Kay, 91 N.J. 159, 172-73 , 450 A.2d 508, 515 (1982)).

11
Morgan v. Lucaskigreen
ri · 1990 · cited in 1 Rhode Island opinions naming this issue, 1992–1992
1 sentence

1992See, e.g., Morgan v. Lucaski, 581 A.2d 714 (R.I.1990).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Rodrigues v. Miriam Hospital green
ri · 1993
1 sentence

2006A corporate negligence claim differs from a respondeat superior claim “in that it imposes on the hospital a nondelegable duty owed directly to the patient that is independent of the doctor-hospital relationship.” Id. at 462 .

12006–2006
Mainella v. Staff Builders Industrial Services, Inc. green
ri · 1992
1 sentence

1998Serv. , 608 A.2d 1141 , 1145 (R.I. 1992).

11998–1998
Fournier v. Miriam Hospital green
ri · 1961
2 sentences

1985This court, in Fournier v. Miriam Hospital, 93 R.I. 299 , 175 A.2d 298 (1961), upheld a statute that limited the effect of the doctrine of respondeat superior, to make charitable hospitals immune from liability for the negligent actions of “officers, agents or employees of the hospital corporation in the management, care or supervision of patients.” Id. at 306 , 175 A.2d at 302 .

1985This court, in Fournier v. Miriam Hospital, 93 R.I. 299 , 175 A.2d 298 (1961), upheld a statute that limited the effect of the doctrine of respondeat superior, to make charitable hospitals immune from liability for the negligent actions of “officers, agents or employees of the hospital corporation in the management, care or supervision of patients.” Id. at 306 , 175 A.2d at 302 .

11985–1985
Fleming v. Bronfin green
dc · 1951
1 sentence

1984Therefore the scope of employment limitation on liability which is a part of the respondeat superior doctrine is not implicit in the wrong of negligent hiring.” Id. 91 N.J. at 172-73 , 450 A.2d at 515 .

11984–1984
State Ex Rel. Department of Justice v. District Court of the Eighth Judicial District green
mont · 1976
2 sentences

1978Department of Justice v. District Court of the Eighth Judicial District, 172 Mont. 88 , 560 P.2d 1328 (1976). 5 This result has been achieved by several courts by strictly applying the doctrine of respondeat superior — if the agent is not liable for his conduct, the principal cannot be responsible.

1978Department of Justice v. District Court of the Eighth Judicial District, 172 Mont. 88 , 560 P.2d 1328 (1976). 5 This result has been achieved by several courts by strictly applying the doctrine of respondeat superior — if the agent is not liable for his conduct, the principal cannot be responsible.

11978–1978
Board of Com'rs of Delaware County v. Briggs green
indctapp · 1975
2 sentences

1978Board of Commissioners v. Briggs, 167 Ind. App. 96 , 337 N.E.2d 852 (1975).

1978Board of Commissioners v. Briggs, 167 Ind. App. 96 , 337 N.E.2d 852 (1975).

11978–1978
Dowler v. . Johnson neutral
· 1918
1 sentence

1949The relation of master and servant does not exist between public officers and their subordinates, and hence it is uniformly held "that public officers are not liable for the negligence of their subordinates unless they cooperate in the act complained of, or direct or encourage it * * *." Dowler v. Johnson, 225 N.Y. 39 .

11949–1949

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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