The Pennsylvania Superior Court held in Coryell v. Morris, 2023 PA Super 232 (2023) that as a matter of law, vicarious liability would not be extended to franchisor Domino's Pizza for a tragic collision between a delivery driver of the franchisee and a motorcyclist. Although the jury awarded $2,109,553 to Clarence Coryell and his wife, Sandra, and against Domino's for vicarious liability, the Superior Court reversed and remanded with instructions that Domino's was not vicariously liable. The case is required reading on the law of vicarious liability for franchise businesses.

The case reinforces the law in Pennsylvania that a mere independent contractor relationship is insufficient to impose vicarious liability. The court affirmed that vicarious liability only attaches in a business relationship where the master "controls not only the result of the work but also has the right to direct the manner in which the work shall be accomplished." The language of the franchise agreement featured prominently in its disposition.