The recent South Carolina case of Johnson v. Atlantic Coast Line R. Co., presents, it is submitted, an undesirable extension of the rule announced in Goddard v. Grand Trunk R. Co. The latter decided that a corporation or principal is liable in punitive damages for a malicious act of its agent committed in the course of, or in connection with, his duties or employment. The prevailing opinion seems to be that the principal is liable (in exemplary damages) only when he has authorized, participated in, or ratified the act of the agent. or was negligent in the selection of his employees. The courts following this view draw no distinction between a principal who is an artificial person (corporation) and one who is a natural person.