A California Court of Appeal has ruled that the "special errand doctrine" may allow an employer to be held liable for personal injuries caused by an employee returning from a business trip.

An employer may be held vicariously liable for the actions of an employee acting within the scope of his or her employment. However, under the "going and coming rule," an employee is not regarded as acting within the scope of employment while going to or coming from the workplace, because the employee ordinarily is not rendering services to the employer while traveling. On the other hand, the "special errand exception" to this rule allows for employer liability where the trip involves a special or incidental benefit to the employer.