Christensen v Swensen (Supreme Court of Utah- 1994)

Princess Leia, onboard the Tantive IV and anticipating the arrival of Darth Vader, employed her astromech droid R2D2 to deliver a frantic plea to the old Jedi Obi-Wan Kenobi, who was hiding on Tatooine.

R2D2, along with his befuddled BFF C3PO, crashed an escape pod onto Tatooine, and began to search for Obi-Wan. Unfortunately, they were quickly captured by Jawas and sold to Owen Lars. Before Owen could wipe their memories and subject them to an eternity of moisture farming, R2D2 was able to outwit the hapless Luke Skywalker and escape into the desert, desperate to complete his mission. However, Luke and C3PO followed him, and R2D2 unwittingly led them straight into a Tusken Raider ambush. After Obi-Wan mysteriously appeared and saved them, Luke (who had taken quite a tumble, and was additionally incensed by the murders of his aunt and uncle) pursued litigation against R2D2 for negligence. Knowing that as a droid, R2D2 would have very few assets, Luke attempted to hold Princess Leia, R2's employer/owner, vicariously liable for her droid's actions.

The lowest court on Tatooine held that an employer was vicariously liable when their employee's negligence occurred within the scope of their employment. Looking to an older case, they found that the test for scope was 3 pronged: The employee must be about the employer's business when the negligence occurs, it must occur within the hours and ordinary spatial boundaries of their employment, and the employee's conduct must be at least partially motivated by serving the employer's interest. The lowest court found, without a jury, that since Tatooine was not within the spatial boundaries of the Tantive IV, Leia was not vicariously liable for R2's negligence.

On appeal to the highest court on the planet, it was decided that vicarious liability is normally a jury issue, and is only decided by the court when there are no factual issues. They held that reasonable minds could differ (that is, there was a factual issue) as to all three criteria, including the spatial limitation. As an astromech, R2D2 was often employed far outside of the Tantive IV, which made the spatial boundaries of his employment hard to determine. The court held that a jury was required to determine the facts before liability was imposed on Leia, and remanded the case for further proceedings.