( Hagerty v. Powers (1885) 66 Cal. 368 [5 P. 622].) At common law, parental liability for a child's tort was imposed only when there was an agency relationship (see, e.g., Kallenberg v. Long (1924) 68 Cal.App. 317 [ 229 P. 57]) or when the parent was himself or herself guilty in some way in the commission of the crime (see, e.g., Ellis v. D'Angelo (1953) 116 Cal.App.2d 310 [ 253 P.2d 675]). California followed this rule of nonliability for parents absent some fault by the parent or the application of a theory of vicarious liability until the enactment of section 1714.1 in 1955. In its original form, section 1714.1 provided: