Lisa Earl, V. City Of Tacoma, Scott Campbell

CourtCourt of Appeals of Washington
DecidedJune 17, 2025
Docket59220-7
StatusPublished

This text of Lisa Earl, V. City Of Tacoma, Scott Campbell (Lisa Earl, V. City Of Tacoma, Scott Campbell) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lisa Earl, V. City Of Tacoma, Scott Campbell, (Wash. Ct. App. 2025).

Opinion

Filed Washington State Court of Appeals Division Two

June 17, 2025

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II LISA EARL, on behalf of and THE ESTATE No. 59220-7-II OF JACQUELINE SALYERS,

Respondent,

v.

SCOTT CAMPBELL; the marital community PUBLISHED OPINION of Scott and Jane Doe Campbell; AARON JOSEPH a/k/a AARON KOMOMUA; and the marital community of Aaron Joseph/Komomua and Jane Doe Joseph/Komomua; and CITY OF TACOMA,

Petitioners.

CRUSER, C.J.—Officer Scott Campbell fatally shot Jacqueline Salyers in 2016. Lisa Earl,

Salyers’ mother, sued Campbell and the City of Tacoma in United States District Court in 2017,

alleging negligence, excessive force, and substantive due process claims. The district court granted

summary judgment for the City, dismissing Earl’s claims. Following the Washington State

Supreme Court’s decision in Beltran-Serrano v. City of Tacoma, 193 Wn.2d 537, 442 P.3d 608

(2019), the district court vacated summary judgment on the state law negligence claims. In 2021,

Earl filed negligence claims against the City and Campbell in Pierce County Superior Court. In

2023, after receiving a report from a police practices expert, Earl moved to amend her complaint

to add a negligence claim against Officer Aaron Joseph, Campbell’s partner, and a claim against No. 59220-7-II

the City for negligent retention of Joseph. The superior court granted Earl’s motion to amend the

complaint. Petitioners sought discretionary review. We granted discretionary review in 2023.1

Petitioners argue that Earl’s negligent retention claim is not viable because Earl alleged,

and the City conceded, that Joseph was acting within the scope of his employment during the

incident in question, and thus agreed that in the event the jury concludes that Joseph acted

negligently in his use of force, the City is vicariously liable for Joseph’s negligence. The City

asserts that where the employer agrees that it is vicariously liable for an employee’s negligence, a

negligent retention claim cannot be simultaneously asserted. In answering the certified question,

we hold that where an employer concedes that its employee was acting within the scope of their

employment during the allegedly negligent act, and that it is vicariously liable for the employee’s

negligence, a simultaneous negligent retention claim is superfluous and cannot be brought.

FACTS

I. BACKGROUND

In January 2016, Tacoma police officers Scott Campbell and Aaron Joseph received a tip

regarding the location of Kenneth Wright, who had numerous outstanding warrants for his arrest.

The informant provided a description of the vehicle Wright was seen in. The officers located a

vehicle that matched the informant’s tip, and found Wright sitting in the passenger’s seat.

Jacqueline Salyers, Wright’s girlfriend, was sitting in the driver’s seat.

1 In an order modifying the commissioner’s grant of review, we limited review solely to the issue certified by the trial court under RAP 2.3(b)(4), and declined review of whether the trial court erred in granting the motion to amend the complaint to add Joseph as a defendant. Ruling Granting Discretionary Rev., Earl v. Campbell, No. 59220-7-II (Wash. Ct. App. April 1, 2024).

2 No. 59220-7-II

According to Joseph’s declaration, upon locating the suspect vehicle, he parked the patrol

car in front of Wright’s vehicle, exited, and approached Wright’s vehicle with his weapon drawn

while commanding Wright and Salyers to show their hands. Campbell also exited the patrol car

and approached Wright’s vehicle. According to Campbell’s declaration, as he observed Wright,

Wright appeared to lean over and reach under his seat. Focused on Wright, Campbell drew his

weapon and approached the passenger side of the vehicle.

As the officers approached, Salyers began inching the vehicle forward. Joseph struck

Salyers’ window with his weapon in an effort to break the window, and as he did, Salyers

accelerated. Joseph stated, “[w]ithin a few seconds of the car accelerating, I heard gunshots and

saw the muzzle flash from the gun.” Clerk’s Papers (CP) at 122. Campbell explained that Salyers

accelerated the car in his direction, causing him to jump backwards and rapidly move away from

the car. At that point, he “fired a volley of shots at the driver,” ultimately hitting Salyers with four

bullets and killing her. Id.

II. PROCEDURAL HISTORY

A. 2017 Complaint

In April 2017, Earl (Salyers’ mother, the personal representative of Salyers’ estate, and the

legal guardian of two of Salyers’ four minor children) filed a federal lawsuit in the United States

District Court for the Western District of Washington. Earl asserted an excessive force claim,

substantive due process claims, and wrongful death claims.2

2 Earl v. Campbell, No. C17-5315BHS, 2019 WL 1403262, at *1 (W.D. Wash. Mar. 28, 2019) (court order), vacated in part, 2020 WL 777205 (W.D. Wash. Feb. 18, 2020) (court order), aff'd, 859 F. App'x 73 (9th Cir. 2021).

3 No. 59220-7-II

In March 2019, the federal court granted the City’s motion for summary judgment. Earl,

2019 WL 1403262, at *4, 9. The court concluded that “Campbell is entitled to qualified immunity

on the Estate’s excessive force claim, Plaintiffs fail to submit sufficient evidence to establish any

substantive due process claim, and Plaintiffs have failed to establish their negligence claims as

asserted in the complaint.” Id. at 4.

Earl filed a motion for reconsideration in July 2019, following our supreme court’s decision

in Beltran-Serrano.3 The court granted Earl’s motion in February 2020, vacating the previous order

in regard to Earl’s state law claims.4 The court reasoned that “reconsideration is warranted because

Beltran-Serrano constitutes a significant change in the law and undermines the Court’s analysis

of their state law claims.” Earl, 2020 WL 777205, at *3. The court declined to exercise

supplemental jurisdiction over the state law negligence claims, dismissed the 42 U.S.C. § 1983

claim with prejudice, and dismissed the state law claims without prejudice. Id. Earl appealed the

district court’s grant of summary judgment regarding the federal claims to the Ninth Circuit. Earl

v. Campbell, 859 F. App’x 73 (9th Cir. 2021). In June 2021, the Ninth Circuit affirmed the district

court’s grant of summary judgment regarding the claims of excessive force, substantive due

process, and denial of access Id. at 73-74, 76.

B. 2021 Complaint

In August 2021, following the federal district court’s order vacating the grant of summary

judgment as to Earl’s state law claims, Earl filed state law negligence claims in Pierce County

3 Beltran-Serrano holds that the fact that an officer’s conduct may constitute an intentional tort does not preclude a negligence claim. Beltran-Serrano, 193 Wn.2d at 540. 4 Earl v. Campbell, No. C17-5315BHS, 2020 WL 777205, at *5 (W.D. Wash. Feb. 18, 2020) (court order), aff'd, 859 F. App'x 73 (9th Cir. 2021).

4 No. 59220-7-II

Superior Court. Again, Earl alleged that Campbell acted negligently in shooting and killing

Salyers, and his negligence caused the wrongful death of Salyers. The complaint alleged that the

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