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Iowa v. Casey’s General Stores, Inc.

Supreme Court of Iowa
587 N.W.2d 599 (1998)


On October 26, 1996, employees at two separate stores, Casey’s General Stores, Inc., and Hy-Vee, Inc. (defendants), sold alcohol to underage customers in a sting operation conducted by local police. The cashiers did not ask for identification to verify the age of the customers. Both corporations had policies in place that banned the sale of alcohol to minors. The defendant corporations were charged under two Iowa statutes with selling alcoholic beverages to an underage person, a simple misdemeanor. The statutes did not specifically impose vicarious liability on employers. Both defendants were found guilty of violating the statutes. On consolidated appeal, the defendants argued that the evidence at trial was insufficient to show that the corporations engaged in criminal conduct. The defendants further argued that the corporations should not be held vicariously liable for the illegal conduct of corporate employees. The district court affirmed the convictions. The defendants appealed.

Rule of Law


Holding and Reasoning (Ternus, J.)

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