On August 16, 2017, the Georgia Court of Appeals affirmed the trial court’s decision that an employer may only be vicariously liable for an employee’s actions if the employer retains control over the time, manner, and method of executing the work. Grange Indem. Ins. Co. v. BeavEx, Inc., 2017 WL 3497486 (Ga. Ct. App. 2017). Pathe Sarr was a delivery driver pursuant to a contract with BeavEx. On March 17, 2014, Sarr was making a delivery to Wells Fargo Bank and collided with the vehicle of Edward and Patricia Morris. The Morrises sued Sarr and BeavEx to recover damages for their injuries sustained in the collision. The court held that Sarr was an independent contractor, not an employee, an

Following an automobile accident in which Russell Brent Musgrove, Sr. and Karen Wallace Musgrove (“the Musgroves”) were killed, their sons (the “Plaintiffs”) filed a wrongful death suit against the other driver and Allstate Property and Casualty Insurance Property (“Allstate”). Allstate Prop. & Cas. Ins. Co. v. Musgrove, 2017 WL 3634124 (Ga. Ct. App. 2017). The Musgroves insured five vehicles with Allstate under two policies with different numbers. They were also covered by additional uninsured motorist (“UM”) coverage with limits of $250,000 per person/$500,000 per accident. The Plaintiffs claimed that the UM coverage applied to both policies. Allstate filed a motion for summary judgme