The Supreme Court in Farmers Ins. Group v. County of Santa Clara (1995) 11 Cal. 4th 992, 1003-1020 47 Cal. Rptr. 2d 478, 906 P.2d 440, reviewed and summarized decisional authority on respondeat superior liability. The court found: "An employer may be subject to vicarious liability for injuries caused by an employee's tortious actions resulting or arising from pursuit of the employer's interests. Vicarious liability may also be proper where the tortious conduct results or arises from a dispute over the performance of an employee's duties, even though the conduct is not intended to benefit the employer or to further the employer's interests. Vicarious liability may even be appropriate for injuries caused after work hours where a dispute arises over the rights and privileges of off-duty employees. In these types of situations, the tortious actions are engendered by events or conditions relating to the employment and therefore are properly allocable to the employer. Conversely, vicarious liability is deemed inappropriate where the misconduct does not arise from the conduct of the employer's enterprise but instead arises out of a personal dispute. In such cases, the risks are engendered by events unrelated to the employment, so the mere fact that an employee has an opportunity to abuse facilities or authority necessary to the performance of his or her duties does not render the employer vicariously liable. In a context more analogous to this case, several decisions have addressed whether an employee's sexual misconduct directed toward a third party is within the scope of employment for respondeat superior purposes. Those cases hold that, except where sexual misconduct by on-duty police officers against members of the public is involved , the employer is not vicariously liable to the third party for such misconduct. In those decisions, vicarious liability was rejected as a matter of law because it could not be demonstrated that the various acts of sexual misconduct arose from the conduct of the respective enterprises. In particular, the acts had been undertaken solely for the employees' personal gratification and had no purpose connected to the employment. Moreover, the acts had not been engendered by events or conditions relating to any employment duties or tasks; nor had they been necessary to the employees' comfort, convenience, health, or welfare while at work." ( Farmers, supra, 11 Cal. 4th at pp. 1005-1007.) In Farmers, the Supreme Court concluded as a matter of law the deputy sheriff was not acting within the scope of his employment when he sexually harassed his coworkers. His motivation was strictly personal and "unrelated to the guarding of inmates or the performance of any other duty of a deputy sheriff at a county jail." ( Farmers, supra, 11 Cal. 4th at p. 1007.) The misconduct was not "precipitated by a work-related dispute . . . ." (Ibid.) The misbehavior had nothing to do with the deputy sheriff's work or that of his victims. ( Id. at p. 1008, 47 Cal. Rptr. 2d 478, 906 P.2d 440.) The Supreme Court held: "Even if the evidence shows that the use of profanity and sexually explicit language was not uncommon at this particular county jail, it still falls far short of establishing that serious misconduct such as asking individual employees for sexual favors and targeting those individuals for inappropriate touching is either typical of or broadly incidental to the operation of a county jail or to the duties and tasks of deputy sheriffs at such a jail.