Smith v. Foodmaker, Inc.
Joe and Georgie Smith appealed a take-nothing summary judgment granted to Foodmaker, Inc. in their wrongful death claim, following the murder of their son, Timothy, at a Fort Worth Jack-in-the-Box restaurant. The Smiths alleged Foodmaker, as franchisor, was vicariously liable for the franchisee's (MDE, Inc.) negligence in providing inadequate security and negligent hiring of the co-worker who committed the murder. The appellate court applied Texas conflicts of law principles, concluding Texas law governed the tort claim despite a California choice-of-law provision in the franchise agreement. Under Texas law, the court found Foodmaker owed no legal duty to Timothy and did not control the specific security or hiring decisions of its independent contractor franchisee. Even if California law were applied, the court determined Foodmaker's control over the franchisee was insufficient to establish an agency relationship for liability. Consequently, the trial court's summary judgment for Foodmaker was affirmed.