Doe v. Boy Scouts of America

Mother sued Boy Scouts (BSA) and their Area Council for sexual abuse of her son by Council executive. Plaintiff failed to establish that executive was employed by BSA, as no showing that it had right to control his work. No liability, under tort theory of negligent retention and hiring, for posttermination acts of executive. No showing that minor had been placed in a worse position by cessation of whatever voluntary protective measures BSA or Council had undertaken, such as "two-deep leadership policy", and neither condoned minor or any youth taking weekend trip alone with adult scout leader. (HUDSON and SPENCE, concurring.)