De La Cruz v. City of Los Angeles

Off-duty police officer Wicks caused an accident while driving on a street near his department's police station after attending a co-workers' retirement party, having taken an indirect route home that didn't match his most direct path; Mercado (plaintiff) sued the City (defendant) under respondeat superior, theorizing Wicks was on a work-related "special errand" returning to the station before heading home. The jury found Wicks negligent but split on whether he acted within the scope of employment, leading to a nonsuit against the City, which the court of appeal found procedurally defective; Mercado sought judicial notice of geographic facts, including the street's proximity to the police station, on appeal.