Arizona Supreme Court
Aaron Engler, an Unmarried Man, Plaintiff/appellant v. Gulf Interstate Engineering, Inc., a Corporation…
July 9, 2012230 Ariz. 55
Summary
The court held that an employer is not vicariously liable for an employee’s after-work automobile accident during an extended out-of-town assignment when the employee was pursuing an independent personal activity outside the employer’s control and not serving the employer’s purposes. It adopted a control-based scope-of-employment test and declined to apply workers’ compensation principles or a contrary rule treating travel to a regular meal as within the scope of employment. The court affirmed the superior court’s summary judgment for the employer and the court of appeals’ judgment.