This Law Firm Publication by Ogletree, Deakins, Nash, Smoak & Stewart, P.C. discusses the Arizona Supreme Court's recent decision in Engler v. Gulf Interstate Engineering, Inc., which held that an employer was not vicariously liable for its employee's off-duty negligent conduct, a car accident during an out-of-town assignment. The accident occurred while the employee was driving back to his hotel after dinner. The employee was not subject to the employer's control at the time of the accident because the employee was not serving the employer's economic interests. Therefore, the employer was not vicariously liable to the victim of the accident. This case is significant for employers because the Arizona Supreme Court declined to extend a recent Arizona Court of Appeals decision, where the court found that an Arizona police officer was acting in the course and scope of his employment when he crashed his state-owned vehicle into the plaintiff's car while going to lunch during an out-of-town business trip.