California, United States of America
The following excerpt is from Creger v. Hudson 141 Homeowners Ass'n, B247480 (Cal. App. 2015):
Plaintiff has not established a probability of prevailing on this claim. A plaintiff pressing a claim for negligent hiring, supervision or retention must not only prove the employee's incompetence; he must also prove that "'the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment . . .'" (Roman Catholic Bishop v. Superior Court (1996) 42 Cal.App.4th 1556, 1564-1565,
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