Iowa v. Casey's General Stores, Inc.
Supreme Court of Iowa
587 N.W.2d 599 (1998)
During a police sting, cashiers at Casey's General Stores and Hy-Vee (defendants) sold alcohol to underage customers without checking identification, even though both companies had policies against such sales, and both corporations were convicted under Iowa misdemeanor statutes for selling alcohol to minors even though those statutes did not expressly impose vicarious employer liability. The defendants argued on consolidated appeal that the evidence could not support corporate criminal liability and that they should not be held vicariously liable for their employees' unauthorized conduct.
Whether, when a criminal statute requires mental fault, an employer must personally know, be willful, or have the requisite intent to commit the crime before being held vicariously liable for an employee's conduct.