Jennifer M. Taylor v. Salem Carriers, Incorporated, et al.

Summary

The United States District Court for the Northern District of Alabama addresses cross-motions for partial summary judgment arising from a motor vehicle accident. The court grants Salem Carriers summary judgment on negligent entrustment and negligent hiring, training, supervision, and retention claims, and grants Taylor summary judgment regarding White’s employment and scope of employment. The court denies White’s motion for summary judgment on Taylor’s wantonness claims, finding factual disputes concerning his conduct before the collision.

Holdings

1. Salem Carriers was entitled to summary judgment because Taylor's evidence of one prior accident, without evidence that White was at fault, and one non-out-of-service equipment-related violation was insufficient to create a genuine issue that White was incompetent to drive or that Salem Carriers knew or should have known of such incompetence.
2. Salem Carriers was entitled to summary judgment on Taylor's negligent hiring, training, supervision, and retention claims because Taylor failed to present evidence from which a jury could reasonably infer that White was incompetent or that Salem Carriers knew or should have known of his alleged incompetence.
3. Taylor was entitled to summary judgment establishing that White was an employee of Salem Carriers and was acting within the line and scope of his employment when the accident occurred.
4. Neither Taylor nor White was entitled to summary judgment on Taylor's wantonness claim against White because conflicting evidence created a genuine dispute of material fact concerning whether White consciously and recklessly accelerated into the intersection or instead attempted to stop and avoid the collision.
5. White was not entitled to summary judgment on Taylor's potential punitive-damages claim because the evidence could permit a reasonable jury to find wantonness by clear and convincing evidence.

Questions Presented

1. Whether Salem Carriers was entitled to summary judgment on Taylor's negligent entrustment claim.
2. Whether Salem Carriers was entitled to summary judgment on Taylor's negligent hiring, training, supervision, and retention claims.
3. Whether Taylor was entitled to summary judgment establishing that White was Salem Carriers' employee and was acting within the line and scope of his employment.
4. Whether either party was entitled to summary judgment on Taylor's wantonness claim against White.
5. Whether White was entitled to summary judgment on Taylor's potential punitive-damages claim.

Disposition

other