The church was found liable for "negligent supervision" of Kriyananda, with a finding of "malice and fraud" on the part of the church.

Most states, including New York, do not grant immunity from liability for negligent supervision or hiring.

One relatively neglected area is the personal liability to non-shareholders that directors may face due to torts committed as a result of negligent supervision.

"He has always maintained that there was negligent supervision during the execution of the search warrant," Mr. London said.

Bo responded in an unusually open press conference during the 2012 National People's Congress, acknowledging "negligent supervision" of his subordinates, saying he may have "relied upon the wrong person".

On March 31, the eight-member jury in Federal District Court here found Brown not guilty of fostering a hostile environment or of negligent supervision.

State investigators across those three decades described many of the homes as little more than psychiatric flophouses, with negligent supervision and incompetent distribution of crucial medication.

Four basic causes of action may arise from such a scenario: negligent hiring, negligent retention, negligent supervision and negligent training.

LaTulippe filed suit on Dec. 10, alleging, among other things, violation of civil rights, negligent supervision, assault and battery and invasion of privacy.

Sexual abuse is plainly not such a purpose, but the supervision of priests, however negligent or improper, probably is.