CRST v. Super. Ct.
B280270M
Cal. Ct. App.Jun 19, 2017Background
- In July 2014 a CRST truck driven by employee Hector Contreras collided with a vehicle carrying Matthew and Michael Lennig, causing serious injuries; CRST later terminated Contreras.
- The Lennigs sued Contreras and CRST (claims included negligent driving, negligent hiring/entrustment/retention) and sought punitive damages against both the driver and CRST.
- CRST admitted vicarious liability for any negligence by Contreras but moved for summary adjudication seeking dismissal of punitive-damage claims and argued Diaz v. Carcamo barred negligent-hiring/entrustment claims when vicarious liability is admitted.
- The trial court granted summary adjudication for Contreras (no triable issue he was intoxicated) but denied CRST’s motion in full; CRST petitioned for writ relief solely as to punitive-damages claims.
- The Court of Appeal held Diaz does not bar punitive damages against an employer that admits vicarious liability, but found no triable issue that would permit punitive damages against CRST under Civil Code § 3294(b) because no managing-agent-level misconduct was shown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an employer’s admission of vicarious liability bars punitive damages against the employer | Lennigs: punitive damages may be awarded if employer misconduct shown | CRST: Diaz/Armenta mean admission of vicarious liability makes employer misconduct evidence superfluous, so punitive damages barred | Court: Diaz/Armenta do not bar punitive damages; admission of vicarious liability does not eliminate §3294(b) inquiry |
| Whether triable issues exist that CRST is liable for punitive damages under §3294(b) (advance knowledge/conscious disregard) | Lennigs: evidence (seatbelt/speeding incident, multiple preventable accidents, policy violations) creates triable issue of advance knowledge and conscious disregard | CRST: complied with federal screening/testing, corrected problems, evidence does not show knowledge of unfitness | Court: triable issue exists as to Davis’s knowledge (seatbelt citation report) but not sufficient on other alleged items (e.g., ‘‘MPH 99’’ is not proof of speeding) |
| Whether any CRST employee shown to have requisite status as a “managing agent” for §3294(b) purposes | Lennigs: Davis (fleet manager) and Stanek (safety supervisor) exercised authority over drivers and safety | CRST: those employees lacked authority to set or change corporate policy—they dispatched and reported to safety/upper mgmt | Court: no triable issue that Davis or Stanek were managing agents with authority to establish corporate policy; absent managing-agent misconduct, punitive damages unavailable against corporate employer |
| Procedural relief — whether writ should issue to prevent trial on nonactionable punitive claim | CRST: trial on punitive claim is nonactionable given lack of managing-agent evidence; writ relief appropriate | Lennigs: factual disputes remain and discovery issues justify denial | Court: granted writ; directed trial court to vacate denial and enter summary adjudication for CRST on punitive-damages requests (discovery arguments forfeited) |
Key Cases Cited
- Diaz v. Carcamo, 51 Cal.4th 1148 (examines Armenta in light of comparative fault; employer admission of respondeat superior liability can render negligent-hiring/entrustment claims superfluous for compensatory allocation)
- Armenta v. Churchill, 42 Cal.2d 448 (pre‑comparative fault rule barring evidence of owner’s negligence when owner admits vicarious liability)
- College Hospital Inc. v. Superior Court, 8 Cal.4th 704 (distinguishes compensatory v. punitive damages; punitive damages require employer fault)
- White v. Ultramar, Inc., 21 Cal.4th 563 (defining "managing agent"—substantial discretionary authority to set corporate policy)
- Grimshaw v. Ford Motor Co., 119 Cal.App.3d 757 (supports punitive damages against enterprises where public-safety deterrence warrants them)