Sandoval v. Leake & Watts Servs., Inc.
Eduardo Sandoval, a nonverbal autistic resident, suffered burns from a heated potato masher at a residential facility operated by Leake and Watts Services, Inc. (L&W). His co-guardians sued L&W, its employees Asialone Edwards and Wendell Chavies, alleging battery, negligence, and negligent hiring, retention, supervision, and training. The Supreme Court denied L&W's and Edwards' motions for summary judgment. The Appellate Division modified this decision, dismissing claims against L&W based on respondeat superior, but affirmed the denial of summary judgment for negligent hiring, retention, supervision, and training claims, and for Edwards' individual claims. The court highlighted L&W's failure to adequately check employee references and that the potential for abuse was foreseeable based on L&W's own training materials.