Since the earliest days of tort litigation, the Virginia Supreme Court of Appeals, like the courts of its sister states, has been committed to the general view that legal responsibility follows negligence, and that the master is liable for his servants' torts committed within the scope of their employment. However, several years before the found- ing of the T. C. Williams School of Law, the Virginia court, in its landmark decision respecting governmental tort immunity, laid down a decision which has led to the creation of a number of tort immunities which it has never sought to justify on grounds of logic, which have not been demonstrated as compelled by precedent, and which have been weakly defended, if at all, on grounds of public policy.

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