Supreme Court of Iowa

Shari L. Martin v. Thomas A. Tovar

June 9, 2023

Summary

The court affirmed summary judgment for the City of Muscatine on claims seeking to hold it vicariously liable for a police officer's sexual assault of a passenger he transported to a hotel. The court held that the assault was an egregious departure from the officer's authorized duties and that Iowa law does not recognize a broad aided-by-agency theory that would impose vicarious liability for intentional torts committed outside the scope of employment.