Section 33 Negligent Retention
| Library | Employer-Employee Law 2008 |
In Gibson v. Brewer, 952 S.W.2d 239, 246 (Mo. banc 1997), involving claims against a Catholic diocese and priest for the priest’s alleged sexual misconduct, the Supreme Court of Missouri treated negligent hiring and negligent retention as identical claims, covering the elements of both in the same sentence.
In Reed v. Kelly, 37 S.W.3d 274, 277–78 (Mo. App. E.D. 2000), the court, citing Gibson, said: “The elements of negligent retention are the same as for negligent hiring.” The facts relevant to the two...
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