deVillers v. County of San Diego, 156 Cal. App. 4th 238 (2007)

Kristin Rossum, who was employed as a toxicologist for the County of San Diego, took toxic materials from the Office of Medical Examiner (“OME”) and used them to murder her husband, Greg deVillers. After Rossum was convicted of murdering deVillers, his survivors sued the County for negligently hiring Rossum and for breaching its duty to guard against the theft of drugs from the OME. The jury awarded damages to deVillers’ survivors, but the Court of Appeal reversed the judgment, holding that there were no legally cognizable claims that could be maintained against the County nor was there a breach of any duty it owed to the survivors.