While an employer cannot be held vicariously liable for torts committed by an employee who is acting solely for personal motives unrelated to the furtherance of the employer's business, the employer may still be held liable under theories of negligent hiring, retention, or supervision of the employee. A cause of action based on negligent hiring, retention, or supervision requires a showing that the employer knew or should have known of the employee's propensity for the conduct which caused the injury and that there is a connection between the defendant's negligence and the plaintiff's injuries.
BCVAWCH-Doe v. Roman Catholic Archdiocese of N.Y., NY Slip Op 00488 (2d Dep't February 4, 2026)
