Dual Purpose Rule Arizona

In Anderson v. Gobea, 18 Ariz. App. 277, 280, 501 P.2d 453, 456 (1972), the Court relied on the "dual-purpose rule" enunciated in workers' compensation cases in concluding that an employee who was involved in an accident while towing the employer's equipment to work with his own truck, pursuant to his employer's instruction, had been acting within the scope of his employment, even though his commute between his home overnight and his work site had also served his personal interests. The Court noted that "although . . . Workmen's Compensation cases and cases arising under similar social legislation are not necessarily authority for principles giving rise to common law liability under the doctrine of respondeat superior, there are instances when the principles are particularly apropos and can be invoked." Anderson, 18 Ariz. App. at 280, 501 P.2d at 456.