Holding Employers Accountable: The Impact of New York Court of Appeals’ Decision on Negligent Supervision and Retention Liability

Employers have a duty to adequately supervise and retain their employees, especially in the financial sector where large sums of money are at stake. When employers fail to fulfill this duty, they may face liability for the damages caused by their employees. The Moore Charitable Foundation v. PJT Partners case is a perfect example of this type of negligence liability. This article will provide a detailed analysis of the case and discuss the lessons employers can learn from it.

Background on the Moore Charitable Foundation v. PJT Partners case: PJT Partners is an investment bank, and Park Hill Group is one of its divisions. The Moore Charitable Foundation hired PJT Partners to manage its assets, and PJT Partners assigned an employee to work on the account of the Moore Charitable Foundation.

The employee’s behavior and actions while working for PJT Partners

The employee succeeded in bringing a substantial amount of work for the employer. However, as time passed, the employee allegedly started showing signs of dangerous and destructive behaviors during work hours. These behaviors included excessive drinking, obsessive personal stock trading, and engaging in unprofessional conduct.

Diversion of $8.1 million fee

In 2014, an employee landed a large deal involving the recapitalization of a private equity fund managed by Irving Place Capital. He ended up diverting the $8.1 million fee to himself for the purpose of purchasing securities through his personal account. This action caused significant financial losses to the Moore Charitable Foundation.

After the deal was closed in 2015, some of the employer’s other workers asked the employee about the delayed payment of the fee. He lied, stating that a “stub closing” had to be completed before the fee would be paid. The employer did not challenge the employee’s explanation or make further inquiries. This lack of due diligence by the employer contributed to the fraud.

The employee was later found out and pleaded guilty to securities and mail fraud charges. He received a four-year sentence of imprisonment for his criminal actions related to diverting the $8.1 million fee.

Foundation’s lawsuit against PJT Partners

The Moore Charitable Foundation sued PJT Partners to recover its losses. The foundation alleged that PJT Partners was liable for negligent supervision and retention, conversion, and fraud.

The Court of Appeals for the State of New York issued a decision reinstating the negligence claim, which the foundation had adequately pleaded. The lower courts should not have dismissed it at the pleading stage. This decision reaffirms that employers must exercise due diligence in supervising their employees to avoid liability for their actions.

Employers’ duty to supervise employees extends beyond customer relationships. Second, the court emphasized that the employer’s duty to supervise its employee did not only extend to dealings with customers. A customer relationship was not a prerequisite for filing a negligent supervision claim. Therefore, employers must supervise their employees in all aspects of their job, regardless of whether or not it involves customers.

Court’s analysis of employee behavior and its implications for employer liability

The court acknowledged that excessive drinking and obsessive personal stock trading might be unprofessional or irresponsible for a financial advisor. However, these acts were not illegal, tortious, or indicative of dishonesty or a propensity to mislead or intentionally harm others. This analysis highlights the importance of employers considering all aspects of their employees’ conduct and behaviors when making decisions about their supervision and retention.

The Moore Charitable Foundation v. PJT Partners case serves as a reminder to employers of their duty to supervise and retain their employees. Negligent supervision and retention can lead to significant financial losses and legal liability. Employers must exercise due diligence in supervising their employees in order to avoid such situations. The court’s decision in this case provides further clarity on the extent of the employer’s duty and their potential liability. Employers should take note of the lessons learned from this case to ensure they are adequately supervising and retaining their employees.

Explore more

Trend Analysis: AI in Automotive Manufacturing

The relentless hum of a modern automotive assembly line is no longer just a mechanical rhythm but a complex digital symphony directed by sophisticated artificial intelligence algorithms. As the manufacturing sector navigates the complexities of the current year, the transition from rigid automation toward cognitive, self-learning systems has become the defining characteristic of industrial competitiveness. This shift represents more than

How Does a Commercial Throughline Drive B2B Growth?

The failure to recognize that larger deal sizes often stem from better brand positioning and buyer education keeps marketing teams stuck in a cycle of under-appreciation. In the high-stakes corporate environment of 2026, the debate over which department truly owns the customer relationship has shifted from a matter of internal politics to a critical business imperative. While CEOs increasingly demand

How Is AI Automation Reshaping Digital Marketing in 2026?

The removal of individual bid caps forces advertisers to prioritize value-based bidding to ensure that high-cost clicks have a high probability of conversion. In the current digital climate, this shift represents more than a technical adjustment; it signifies a complete overhaul of the relationship between human intuition and machine efficiency. As major advertising networks transition toward a state of total

How Is Federal Policy Reshaping Legal and Labor Boundaries?

A pivotal Department of Justice opinion letter argues that long-standing federal guidelines for evaluating systemic discrimination are inconsistent with both Title VII and the Constitution. This bold legal assertion marks a definitive turning point in how the current administration views the limits of regulatory agency power. We are witnessing a systemic dismantling of the traditional administrative state, replaced by a

How to Fix Performance Issues on macOS Golden Gate

Startup disk congestion remains a primary cause of system instability because macOS requires significant free space for swap files, temporary caches, and seamless background software updates. When Apple released macOS 27 Golden Gate, users of M1 and M2 devices experienced a shift in how the operating system handles the vast Unified Memory Architecture. This change often results in an initial

Fill out the form below