Jose Rivera v. State of New York
This New York Court of Appeals case addresses the State's vicarious liability for an assault committed by correction officers on an inmate. The inmate, Jose Rivera, was brutally attacked by Officer Michael Wehby and restrained by other officers, Femia and LaTour. The Court of Claims and Appellate Division found Wehby's actions were outside the scope of employment. The Court of Appeals affirmed, holding that Wehby's unprovoked and excessive force was a significant departure from his duties, thus precluding vicarious liability under respondeat superior. The dissenting judges argued that there were triable issues of fact regarding whether the other officers, who restrained Rivera, acted within the scope of their employment, potentially believing they were maintaining prison order.