Missouri Court Rules No-Go on Expanding the Logo Liability Doctrine

Paulette Anthony was driving when a truck crossed into her lane, causing a collision that seriously injured Lisa Hearn; although the truck fled and was never identified, Hearn claimed it bore ABF signage and sued under the theory of logo liability. While Missouri courts have expanded logo liability to allow presumptions of vicarious liability based on a carrier’s signage, the doctrine is rooted in carrier–independent contractor relationships, not employer–employee ones. In Hearn v. ABF Freight System, Inc., the court refused to extend the doctrine further and affirmed judgment for ABF because the Hearns failed to show ABF operated as a carrier-lessee or that the unidentified driver acted within the scope of employment.