The Texas & Pacific Railway Company v. Paul Hagenloh

Summary

The Texas & Pacific Railway Co. v. Hagenloh held that the railway was not liable for the assault of its former special agent because the agent acted outside the scope of his employment, driven by personal animosity rather than in furtherance of the company's business. The majority reversed the trial and appellate courts' judgments, granting judgment for the railway; Justice Smith dissented, arguing that the employer could be liable under the broader scope‑of‑authority test.