Samson v. Riesing

In Samson v. Riesing, 62 Wis. 2d 698, 710, 215 N.W.2d 662 (1974), the Court recognized that "vicarious liability ... and joint venture are essentially doctrines that are applicable to a situation where the negligence of one party is proved and it is sought to hold another party liable." The court further recognized that these doctrines are of no assistance to a plaintiff "where the onus of negligent conduct has not been placed on any defendant." Id.