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United States Fourth Circuit

Antonio v. SSA Security, Inc., 13-1031

In this case, plaintiffs seek to hold defendant SSA Security responsible for a residential arson that was allegedly committed by one of its security guards. The district court granted summary judgment to SSA on plaintiffs' negligence-based claims and on their claim under the Maryland Security Guards Act (MSGA), concluding that the MSGA merely codified and did not expand the common-law doctrine of respondeat superior with regard to security companies. The judgment is affirmed, where MSGA section 19-501 does not impose liability beyond the common law principles of respondeat superior such that an employer would be responsible for the off-duty criminal acts of an employee, even if the employee planned any part of the off-duty criminal acts while he or she was on duty.

Appellate Information

  • Decided 04/03/2015
  • Published 04/03/2015


  • Floyd


  • United States Fourth Circuit


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