LaPlant v. Snohomish County

Leach, A.C.J.

¶1 On discretionary review, we must decide whether a negligent training and supervision claim should be dismissed when an employer, against whom vicarious liability is also alleged, admits that its employees’ allegedly negligent conduct occurred within the scope of employment. We hold that the trial court should have dismissed Mario LaPlant’s cause of action for negligent training and supervision against Snohomish County because under the facts of this case, this claim is superfluous. Accordingly, we reverse.

FACTS

¶2 In June 2003, Snohomish County deputy sheriffs initiated and…