In a recent decision by the Arizona Court of Appeals, Division Two, the court upheld a jury verdict in favor of Casas Custom Floor Care, LLC, in a wrongful death lawsuit filed by Michael Corey Cravens. The case stemmed from an April 2018 motor vehicle accident involving Martin A. Montano Jr., an employee of Casas, which resulted in the death of Samantha J. Cravens. Michael Cravens, her surviving spouse, alleged that Montano was acting within the scope of his employment at the time of the accident and sought damages for wrongful death and negligence.
The appeal primarily addressed whether Montano was acting within his employment scope when he caused the fatal collision while driving to correct his timesheet at Casas’s office. The court found sufficient evidence supporting the jury’s determination that Montano was not acting within his employment scope at that time. Additionally, issues regarding jury instructions and evidentiary rulings were discussed but ultimately did not alter the trial court’s judgment.
The court also examined whether certain evidence should have been admitted or excluded during the trial. It concluded that excluding testimony from Cravens’s expert on federal labor law was appropriate as it could confuse jurors about state law concerning employment scope.
This ruling emphasizes legal interpretations around vicarious liability and reinforces employer defenses against claims arising from employee actions outside their work duties.
Source: CV20230250_Cravens_v_Casas_Custom_Floor_Care_LLC_Opinion_Arizona_Court_of_Appeals.pdf