Jackson v. AEG Live, LLC

— Plaintiff Katherine Jackson, on behalf of herself and as guardian ad litem of Michael Joseph Jackson, Jr., Paris-Michael Katherine Jackson and Prince Michael Jackson II (collectively, the Jacksons), appeals from a judgment in favor of defendants AEG Live, LLC, AEG Live Productions, LLC, Brandon Phillips, and Paul Gongaware (collectively, AEG) in this negligence action in connection with Michael Jackson’s (Michael) death. AEG hired Dr. Conrad Murray as Michael’s personal physician for a concert tour. Michael died of acute propofol intoxication while under Dr. Murray’s care. The Jacksons filed this action seeking to hold AEG liable on theories of negligence. The trial court summarily adjudicated causes of action for negligence and respondeat superior. The sole cause of action at trial was for negligent hiring, retention, and supervision. The jury found AEG hired Dr. Murray; however, he was not unfit or incompetent to perform the work for which he was hired.

On appeal, the Jacksons contend that the trial court erred by granting summary adjudication, because (1) triable issues of fact exist as to whether AEG was negligent, because AEG’s conduct created an increased risk of…