At common law, the majority of states held that a tort claimant's release of either an employer whose sole liability was vicarious or the employee who had committed the tort operated to release the other. Washington follows this position for releases of an employee, but Vanderpool v. Grange Insurance Association announces a different rule for releases of an employer. This Note examines Vanderpool in view of relevant public policies, statutes, and prior case law and recommends adopting a rule that the release of a solvent employer operate to release its employee-tortfeasor.
Karen P. Clark,
"Respondent Inferior": The Rule of Vanderpool v. Grange Insurance Association, 110 Wash. 2d 483, 756 P.2d 111 (1998)?,
64 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol64/iss2/7