Can an employer be held liable for tortfeasor-employee negligence in the context of a motor vehicle accident?

employer violated a duty of care it owed to the injured party and this negligence was a proximate cause of the resulting injury (the direct liability theory), or (2) the tortfeasor-employee was liable for committing the tortious conduct that caused the injury while acting within the course and scope of his or her employment (the vicarious liability theory). [Citation.] When the employer is a governmental agency, the statutory framework permits the injured party to pursue the vicarious liability theory in accordance with these general common law principles. [Citation.] However, the statutory framework requires, as a condition to the injured party's recovery on a direct liability theory against a governmental agency, that the injured party identify a specific statute declaring [the entity] to be liable, or at least creating some specific duty of care by the agency in favor of the injured party. [Citations.]" ( de Villers v. County of San Diego (2007) 156 Cal.App.4th 238, 247-248, 67 Cal.Rptr.3d 253, fn. omitted ( de Villers ).)