Chad Seward, Home Depot U.S.A., Inc., and Point 2 Point Global Security, Inc. v. Rogelio Santander Sr. and Julia Garcia, Individually and as Co-Administrators of the Estate of Rogelio Santander Jr., and Crystal Almeida
Justice Busby's concurring opinion addresses a case involving an off-duty police officer, Chad Seward, who was working as a private security guard for Home Depot and was allegedly negligent, leading to injuries to on-duty officers. The main Court's opinion dismissed claims against Seward due to immunity and reinstated summary judgment for Home Depot and Point 2 Point on vicarious liability claims. Justice Busby highlights that the Court's decision deliberately avoids the significant question of whether employers can be vicariously liable for the torts of off-duty police officers acting within the scope of public employment. The opinion discusses various judicial approaches to this complex issue, contrasting the 'nature of the act' and public policy approaches with the agency law framework adopted by Tennessee courts. Justice Busby concludes by joining the Court's opinion and advocating for future cases to thoroughly explore these considerations within Texas law.