The Appellate Group

Sampson v. HB Boys

Sampson v. HB Boys, 2024 UT App 56 (Mortensen, J.)

Civil Procedure/Statutory Interpretation

After two altercations with a shift supervisor, Plaintiff sued a fast food chain under the Utah Civil Rights Act (UCRA). The fast food chain moved for summary judgment, claiming the common law doctrines of respondeat superior and agency did not apply and that it was not liable under the UCRA. The district court granted the motion. Plaintiff appealed. The Utah Court of Appeals reversed, holding:

  • The doctrine of respondeat superior applies to the UCRA’s private cause of action section. Applying that to the facts of the case, there was a dispute of material fact, precluding summary judgment. 
  • Practice tip: Common law principles, including the doctrine of respondeat superior, apply in the context of UCRA cases.

Read the full court opinion