In Underwriters Ins. Co. v. Purdie (1983) 145 Cal.App.3d 57, the court explained: "There is a division of authorities on whether negligent hiring may serve as an independent basis for an employer's liability to a third person. One line of cases is to the effect that an employer's failure to hire only competent and proper employees does not of itself constitute an independent ground of actionable negligence. In other words, if liability to a third person for the act of an employee is to exist, it must be predicated upon the wrongful act or omission of the employee, and not upon the care or lack of it exercised by the employer in selecting the employee. The other view, however, which California follows, is that an employer may be liable to a third person for the employer's negligence in hiring or retaining an employee who is incompetent or unfit. The rule is stated in Restatement Second of Agency section 213: 'A person conducting an activity through servants ... is subject to liability for harm resulting from his conduct if he is negligent or reckless: ... (b) in the employment of improper persons ... involving the risk of harm to others: ...' Comment d reads in part: 'The principal may be negligent because he has reason to know that the servant ... , because of his qualities, is likely to harm others in view of the work ... entrusted to him. ... An agent, although otherwise competent, may be incompetent because of his reckless or vicious disposition, and if a principal, without exercising due care in selection, employs a vicious person to do an act which necessarily brings him in contact with others while in the performance of a duty, he is subject to liability for harm caused by the vicious propensity ... Liability results under the rule ... , not because of the relation of the parties, but because the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment. ...' "