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Case Citations [i] (Spring 2026)

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                            THE AMERICAN


                            LAW INSTITUTE



                                    Spring 2026 Citations



                                 JUDGMENTS



        CHAPTER 4. EFFECT OF JUDGMENTS WITH REFERENCE TO PERSONS

                      TOPIC  2. PERSONS   NOT  PARTIES   OR  PRIVIES

§ 99. Where Liability of a Person is Based Solely upon the Act of Another

Wash.App.2024.  Cit. in disc. Former resident of a group home for foster children sued various corporate
entities related to the home, alleging that defendants were vicariously liable for the negligence of the
home's governing boards in supervising the home's employees and residents, which proximately caused
resident to be subjected to abuse while living in the home. The trial court granted summary judgment for
defendants. This court reversed in part and remanded, holding that the protections of the state's
corporate dissolution survival statute, which barred liability against the home's now-dissolved governing
boards, did not extend to defendants. The court reasoned that ajudgment that discharged an agent only
protected a principal from derivative responsibility for the agent's actions when the judgment was on the
merits and not based on a personal defense, and dismissal under the corporate dissolution survival
statute was more accurately construed as a personal defense, similar to dismissal pursuant to a statute-of-
limitations defense under Restatement of Judgments § 99, which did not result in a dismissal on the
merits. CC. v. Kiwanis International, 568 P.3d 677, 687.















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