LaPlant v. Snohomish County
162 Wash. App. 476
| Wash. Ct. App. | 2011Background
- In June 2003, Snohomish County deputies pursued a stolen vehicle, causing a fatal collision that injured LaPlant.
- LaPlant sued Snohomish County, asserting vicarious liability for the deputies’ negligence in the pursuit.
- LaPlant and Pennamen’s actions were consolidated.
- LaPlant amended to add a negligent training and supervision claim against the County; the County moved to dismiss as redundant.
- The trial court denied the motion; the County sought discretionary review.
- The court held the negligent training and supervision claim should be dismissed as superfluous when the employer concedes vicarious liability for within-scope conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether negligent training/supervision claim should be dismissed as redundant | LaPlant argues training claim is independent. | County argues vicarious liability makes training claim redundant. | Yes; training claim should be dismissed as superfluous. |
Key Cases Cited
- Gilliam v. Dep’t of Soc. & Health Servs., 89 Wn. App. 569 (1998) (negligent supervision dismissed when employee acted within scope; vicarious liability forecloses separate claim)
- Joyce v. Dep’t of Corr., 116 Wn. App. 569 (1998) (redundancy of vicarious liability and negligent supervision claims)
- Niece v. Elmview Grp. Home, 131 Wn.2d 39 (1997) (negligent hiring/retention/supervision distinct from vicarious liability)
- Briggs v. Nova Servs., 135 Wn. App. 955 (2006) (negligent supervision elements and employer duty)