In Estate of Arrington v. Fields, 578 S.W.2d 173 (Tex.Civ.App.1979), the Texas Court of Appeals cited several Texas cases involving negligent entrustment and negligent hiring, some of which indicate that where "ordinary negligence is alleged ... negligent hiring and respondeat superior are mutually exclusive modes of recovery." Id. at 178. The Texas Court of Appeals noted other cases, however, holding that where a plaintiff has alleged ordinary negligence against the employee and gross negligence against the employer for hiring or entrusting the employee to carry out hazardous duties, the negligent hiring or entrusting cause of action would be an independent and separate ground for recovery. To distinguish between the two situations, the Texas Court of Appeals in Arrington pointed to a "discernable pattern" wherein the primary factor "is whether or not punitive damages are sought by the plaintiff." Id. at 178.