White v. Revco Discount Drug Centers, Inc.

Off-duty officer Boone worked security for Revco (defendant), which hired him partly for his authority to issue citations; when a shoplifter Boone had cited failed to appear, Boone's Revco supervisor directed him to serve an arrest warrant at Woodfin's apartment, and during that arrest -- interrupted midway when Revco called Boone back to the store for another citation before he returned to complete it -- police shot and killed Woodfin. Woodfin's family (plaintiffs) sued Revco for wrongful death on a vicarious-liability theory; the trial court dismissed for failure to state a claim, and the family appealed.

Whether a principal may be held liable for an agent's tortious act when the principal directed the act, even if the act falls outside the normal scope of the agency.