14

Lund v. Capel, 675 P.2d 226 (Wash. 1984); Destefano v. Grabian, 763 P.2d 275 (Colo. 1988) (the court ruled that the church and a parent denomination might be liable on the basis of negligent hiring or negligent supervision); Erickson v. Christenson, 781 P.2d 383 (Or. App. 1989) (the court ruled that the church and a parent denomination might be liable on the basis of negligent hiring or negligent supervision); J. v. Victory Baptist Church, 372 S.E.2d 391 (Va. 1988) (the court ruled that the church was not be liable on the basis of respondeat superior, but might be liable on the basis of negligent retention or supervision if it were aware of previous incidents of misconduct but did nothing to monitor the employee's behavior).