Engler v. Gulf Interstate Eng’g, Inc.

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In this case, the Supreme Court addressed whether an employer can be held vicariously liable for an after-work accident caused by an employee who was on an extended away-from-home assignment. The accident occurred when the employee was driving back to his hotel after dinner. The trial court granted summary judgment in favor of the employer. The court of appeals affirmed, holding that an employee on out-of-town travel status is not acting within the course and scope of his employment while traveling to or from a restaurant for a regular meal. The Supreme Court affirmed, holding that because the employee was not subject to his employer's control, he was not acting within the scope of his employment at the time of the accident, and therefore, the employer was not liable for the employee's actions.