Clerk Failed to Prove Her Employer's Conduct Made Armed Robbery 'Substantially Certain' to Occur

A Louisiana appellate court ruled that a convenience store manager trainee could not maintain a tort suit against her employer since she failed to establish that her employer’s conduct had made it “substantially certain” she would be robbed at gunpoint while she was attempting to make a bank deposit. Case: Smith v. Sam, No. 17-664, 02/07/2018, published. Facts and Procedural History: Melody Smith worked as a manager-trainee for Circle K Stores. On Sept. 21, 2013, she was robbed at gunpoint while attempting to make a bank deposit for Circle K. According to Smith, the gunman...