Chad was just hired as a delivery driver for Speedy Senders, LLC, a large distribution company located in Washington state. His job is to simply deliver products to the buyer. He drives a large semi-truck. While Chad’s truck is being loaded, he has time to walk around the shop and to talk with his colleagues. He enjoys connecting with his fellow employees. However, John, the shop supervisor, despises Chad. Whenever John sees Chad, he never misses an opportunity to chastise and to belittle him. For example, John has told Chad on several occasions that Chad is “a good-for-nothing”, and that Chad is “damn lucky to have this job because I would have never hired you”. John has even gone so far as to make fun of Chad’s physical appearance, calling him “fat” and “ugly”. Chad takes John’s attacks very personally and he has been deeply affected by them. In fact, Chad has been so hurt by John’s attacks that Chad is finding it difficult to work. Chad informs the owners of Speedy Senders, but they take no action.

Chad has had enough. One day, Chad decides that, while he is on his delivery route, he is going to intentionally crash his truck into John’s car while John is in it. So, one day, as Chad is pulling out of the shop, he collides into the passenger side of John’s car, completely totaling the car and injuring John who was inside. John exits his car yelling and screaming at Chad, accusing him of doing it on purpose. For his part, Chad denies that he did it intentionally and that it was caused by a defect in the truck.

After an internal investigation, the owners of Speedy Senders conclude that there was no defect in the truck and that Chad caused the collision on purpose. Chad was promptly fired. Chad then files a lawsuit against Speedy Senders for hostile work environment. John files a lawsuit against Chad for battery and for intentional infliction of emotional distress. John includes Speedy Senders as a defendant in the lawsuit based on the theory that it is liable as Chad’s principal.

You are the lawyer for Speedy Senders and you have to defend against these claims. What will your defenses be? Will they be successful? Please explain your answer.