Section 34 Negligent Training

• Library: Employer-Employee Law 2008

In J.M. v. Shell Oil Co., 922 S.W.2d 759 (Mo. banc 1996), the plaintiff was abducted from outside a convenience store and gas station, assaulted, and raped. She sought to recover against the franchisor, Shell, on a variety of theories, including that Shell was negligent in its security training of employees. On appeal from summary judgment in favor of Shell, the court of appeals opined that there were triable issues, but immediately granted transfer to the Supreme Court of Missouri because of the importance of the issues.
J.M. v. Shell Oil Co., No. 67556, 1995 WL 713052 (Mo. App. E.D. Dec. 5, 1995).

The plaintiff argued that Shell was liable...