In Diaz v. Carcamo (2011) 51 Cal.4th 1148, the California Supreme Court analyzed a negligent retention claim in the context of an accident-prone truck driver. In doing so, the California Supreme Court defined the relevant negligent retention claim as follows: "Awareness, constructive or actual, that a person is unfit or incompetent to drive underlies a claim that an employer was negligent in hiring or retaining that person as a driver. (See Judicial Council of Cal. Civ. Jury Instns. (2011) CACI No. 426.)" (Diaz v. Carcamo, supra, 51 Cal.4th at p. 1157.)