Santiago v. Phoenix Newspapers, Inc.
Arizona Supreme Court
794 P.2d 138 (1990)
- Written by Craig Conway, LLM
Facts
William Santiago (plaintiff) was seriously injured when a vehicle driven by Frank Frausto (defendant) collided with his motorcycle. At the time of the incident, Frausto was delivering the Sunday edition of the Arizona Republic newspaper as an independent contractor for Phoenix Newspapers, Inc. (PNI) (defendant). Santiago filed a negligence suit against Frausto and PNI alleging the newspaper company was vicariously liable for Frausto’s actions. Frausto and PNI moved for summary judgment on the vicarious liability claim. The trial court concluded, based on the agreement signed between Frausto and PNI, that Frausto was an independent contractor and granted summary judgment. In making its ruling, the trial court carefully considered the affidavit of Frausto who stated that, despite the contractual agreement stating that he was not a PNI employee, he considered himself to be one and delivered the papers as directed by a supervisor, including placing the paper in a particular spot if requested by a customer. Santiago appealed. The court of appeals affirmed the judgment of the trial court. The Arizona Supreme Court granted certiorari to review.
Rule of Law
Issue
Holding and Reasoning (Grant, C.J.)
What to do next…
Here's why 964,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 47,500 briefs, keyed to 1,006 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.
- AI-generated podcast version of every brief — listen on the go, between classes, or whenever reading isn’t an option. New
Understand your casebook readings in seconds
Use our case briefs to comprehend your casebook readings faster, supplement your notes and outlines, and outshine your peers in class.
Get instant access to over 47,500+ expert-written case briefs in a searchable database keyed to 1,006 law school casebooks.




