Missouri Court of Appeals, Eastern District / Aug 11, 2020
Lisa Hearn and Daniel Hearn, Appellants, vs. ABF Freight System, Inc., Respondent.
Lisa and Daniel Hearn appealed a jury verdict in favor of ABF Freight System, Inc. on their negligence and loss of consortium claims, stemming from a motor vehicle accident involving an unidentified truck bearing ABF signage. The Hearns argued that the trial court erred by denying their motion for a directed verdict and by improperly instructing the jury on traditional agency principles, contending the logo-liability doctrine should have applied. The appellate court affirmed the trial court's judgment, holding that the logo-liability doctrine was inapplicable because the Hearns failed to present evidence that ABF operated as a carrier-lessee, a prerequisite for the doctrine's application.