You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Finkle v. Regency CSP Ventures Ltd. Partnership

Citations: 27 F. Supp. 3d 996; 2014 U.S. Dist. LEXIS 82850; 2014 WL 2767374Docket: No. CIV 13-4019

Court: District Court, D. South Dakota; June 18, 2014; Federal District Court

Narrative Opinion Summary

In a negligence action arising from a motorcycle accident, Plaintiffs allege liability against Defendants under the doctrines of respondeat superior and negligent supervision and training. The incident involved an employee of the Defendant corporation, operating a Jeep, allegedly causing the accident by improperly positioning the vehicle. Defendants sought partial summary judgment, arguing the redundancy of negligent supervision and training claims given the employee's acknowledged actions within her employment scope. The court examined whether these claims could proceed in the absence of conflicting state law or direct Supreme Court rulings, drawing on analogous jurisprudence. Plaintiffs argued the Defendants failed to provide adequate training for unique driving situations, such as wildlife viewing stops, which contributed to the incident. Furthermore, the court considered claims of comparative negligence among all parties involved. Ultimately, the court denied the Defendants’ motion for partial summary judgment, finding sufficient grounds for a jury to assess the claims of negligent supervision and training, thereby allowing these claims to proceed to trial.

Legal Issues Addressed

Comparative Negligence

Application: The court determined that the negligence claims should include comparative analysis of all parties involved.

Reasoning: The issue of comparative negligence was raised, with Plaintiffs asserting that both Defendants' negligence in training and supervision, as well as driver negligence, should be considered alongside the alleged negligence of Philip Finkle.

Negligent Supervision and Training

Application: The court evaluated whether the lack of specific training regarding safety protocols constituted negligence warranting jury assessment.

Reasoning: Plaintiffs contend that Defendants failed to adequately instruct their employees regarding safety protocols when stopping along the wildlife loop road for wildlife viewing, specifically neglecting to direct them to use designated pullouts.

Procedural Decision on Motion for Summary Judgment

Application: The court denied the motion for partial summary judgment, allowing the claims of negligent supervision and training to proceed.

Reasoning: Consequently, the Court denied Defendants’ Motion for Partial Summary Judgment concerning the Plaintiffs’ claims of negligent supervision and training.

Respondeat Superior and Employer Liability

Application: The court considered whether the admission of an employee acting within the scope of employment negates the need for independent claims of negligent supervision and training.

Reasoning: Defendants argue that Plaintiffs’ claims of negligent supervision and training are redundant since they acknowledge that Funk, an employee, was acting within her employment scope during the incident on August 6, 2012.