Cotton States Mutual Insurance v. Kinzalow

Bernes, Judge.

Appellees Jennifer Kinzalow and Mary Ann Lamay sued their former employer, Cotton States Mutual Insurance Company, and their former supervisor, Michael Sweet, asserting various claims against Sweet stemming from allegations that he recorded activity within their office without their knowledge or consent. They also seek to hold Cotton States directly and indirectly liable for Sweet’s conduct. Cotton States appeals the trial court’s denial of its motion for summary judgment on all substantive claims. For the reasons set forth below, we reverse.

The standard of review of the denial…