In Shook v. Beals (1950) 96 Cal. App. 2d 963, the defendants were sued under joint venture, joint enterprise, or joint adventure theories. Shook stated that some authorities hold that the later theory "applies to undertakings for the mutual benefit or pleasure of the parties. " (Id. at p. 968.) In Shook, the defendants were collectively liable for damage to a plane they had leased for a fishing trip. Liability was imposed because the defendants jointly paid and hired the plane and each had the right to control it.