Arizona Supreme Court: Sherold D. Roaf v. Rebuck Consulting, LLC, et al
Case No. CV-23-0233-PR Filed June 25, 2024
ISSUES:
- Whether evidence of negligent hiring should be admitted when an employer has admitted vicarious liability and there is no claim for punitive damages.
- Whether the admission of such evidence prejudiced the defendant, warranting a new trial.
DECISIONS:
- The court held that evidence related to negligent hiring should not have been admitted as it was irrelevant to the only issue before the jury: the amount of compensatory damages.
- The court found that the defendant was prejudiced by the erroneous admission of this evidence, warranting a new trial.
Synopsis:
In this case, Sherold D. Roaf sued Francisco Ortiz for negligence and Medstar (Ortiz’s employer) for vicarious liability and negligent hiring after a rear-end collision. Medstar admitted full liability for both claims, and Roaf did not seek punitive damages. The trial court allowed evidence of Ortiz’s driving record and Medstar’s hiring practices, instructing the jury to apportion fault between Ortiz and Medstar. Roaf’s counsel used the evidence to argue for punishing Medstar, despite the absence of a punitive damages claim. This ruling clarifies the application of vicarious liability and negligent hiring claims in Arizona, particularly in cases where only compensatory damages are sought. It emphasizes the importance of relevance in evidence admission and the potential for prejudice when irrelevant evidence is presented to a jury.
Outcome of the Case:
The Arizona Supreme Court vacated the court of appeals’ memorandum decision, reversed the trial court’s ruling, and remanded the case for a new trial.