Frazier v. State
Justice Alexander dissents from the judgment affirming the dismissal of Kevin Frazier's complaint against the State of New York. The case arises from an incident on October 10, 1979, where off-duty correction officer Robert Warner, acting as a peace officer, pursued robbers and accidentally shot Frazier while discharging his personal firearm. The lower court dismissed the complaint, finding the State not vicariously liable as Warner was off-duty and thus not within the scope of his employment. Alexander, J., argues that as a peace officer, Warner had a duty to make arrests, and the State maintained control over his weapon use, even off-duty, making his actions foreseeable within the scope of employment under the respondeat superior doctrine. Therefore, the judgment should be reversed, and the complaint reinstated.