This Law Firm Publication by Jackson Lewis P.C. discusses Montague v. AMN Healthcare, Inc., in which a California Court of Appeal held that a medical staffing company was not vicariously liable for its medical assistant who poisoned a coworker while on assignment at a hospital. The court granted the company's summary judgment motion, ruling that the employee's highly unusual and startling actions were outside the scope of her employment and that the plaintiff failed to present any evidence that she had previously complained about the medical assistant or that the poisoning was motivated by prior work-related disputes. The court also dismissed the plaintiff's negligent training claim because the company did train its employees on avoidance of workplace violence and her claim was merely speculative.