Ii. [§ 3.195] Respondeat Superior

• Jurisdiction: Maryland

II. [§ 3.195] RESPONDEAT SUPERIOR

John Smith is a security guard for the ABC Food Market, a grocery store owned by ABC Food Mart, Inc. One evening, George Harris entered ABC Food Mart to purchase a quart of milk. Harris, who was returning from a day at the beach, was barefoot. Smith asked Harris to leave the store. When Harris refused to leave the store, Smith pushed Harris to the floor and hit him on the head several times with a blackjack causing Harris to sustain injuries.

Harris sought recovery against ABC Food Mart, Inc. for the injuries inflicted by Smith's assault, based upon the doctrine of respondeat superior.

COMPLAINT

Respondeat Superior

George Harris (hereinafter "Harris"), Plaintiff, by his attorneys, Grace P. Hwang and Hwang & Hwang, P.A., sues ABC Food Mart, Inc. (hereinafter "ABC Food Mart"), Defendant, and states:
1. Plaintiff Harris is a resident of Baltimore City, Maryland.
2. Defendant ABC Food Mart is incorporated in the State of Maryland, where it is engaged in the business of retail sales of groceries and sundries. ABC Food Mart owns and operates the ABC Food Mart store located at 123 Green Street, Baltimore City, Maryland.
3. At all times relevant hereto, John Smith was employed by ABC Food Mart as a security guard for the ABC Food Mart located at 123 Green Street in Baltimore City, Maryland.
4. At approximately 6:30 p.m. on May 9, 2021, John Smith, while on duty as a security guard, without provocation, intentionally struck Plaintiff Harris several times with a blackjack inside the ABC Food Mart at 123 Green Street, Baltimore City, Maryland causing Plaintiff to sustain severe injuries.
5. The above described acts of John Smith were committed within the scope of his employment with ABC

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