Punitive Damages Exception Recognized to General Rule Precluding Direct Liability Against Employers who Admit Vicarious Liability for Emplyoees' Negligence

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The Court of Appeals for the Western District of Missouri has answered in the affirmative a question left open by the Missouri Supreme Court almost two decades ago: whether a claim for punitive damages can in fact serve as an exception to the general rule that once an employer had admitted respondeat superior liability for an employee's negligence, it is improper to allow a plaintiff to proceed against the employer on any other theory of imputed liability.

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