Corporations act only through human agents. In King v. McGuff in 1950, the Texas Supreme Court adopted Section 909 of the Restatement of Torts. Section 909 bars an employer's liability for an employee's grossly negligent act, unless: 1) the employer authorized the manner and the doing of the act, 2) the employee was unfit and the employer was reckless in employing him, 3) the employee was employed as a vice principal or in a managerial capacity and was acting in the scope of his employment, or 4) the employer ratified and approved the employee's act. Comparably few Texas appellate courts address ratification in tort cases, but courts analyzing the issue have held ratification may occur when the employer or its vice principal confirms, adopts or fails to repudiate the employee's acts.