Nears v. Holiday Hospitality Franchising, Inc.
Sharon Nears appealed the entry of summary judgments in favor of Holiday Hospitality Franchising, Inc. (HHFI) and Six Continents Hotels, Inc. Nears had sued for wrongful termination and intentional infliction of emotional distress, alleging her supervisor, Jack Marshall, engaged in abusive behavior while she worked at a Holiday Inn hotel managed by ETEX Hotel Management Co., Inc. Nears contended that HHFI was vicariously liable for Marshall's and ETEX's actions based on theories of actual and apparent authority. The appellate court affirmed the summary judgments, finding Nears failed to present a genuine issue of material fact regarding HHFI's control over Marshall's supervisory interactions with Nears, thus precluding a finding of actual or apparent agency.