In Quinonez v. Anderson, 696 P.2d 1342, 1344 (Ariz. Ct. App. 1984), defendant Anderson negligently ran a red light and killed the plaintiff's wife. Id.

¶ 9 Chad and Marsha argue Sedillo is "squarely on all fours with the present case" because "there was no impeachment, contradiction or refutation of the evidence of [their] close family relations with John." In response, GABA argues Sedillo is distinguishable because the plaintiffs in that case, unlike Chad and Marsha, "proved specific pecuniary losses" from the decedent's death, and evidence of financial loss is required, relying on Quinonez v. Andersen, 144 Ariz. 193, 696 P.2d 1342 (App. 1984). We disagree.

¶33 The superior court did not err in admitting this evidence because it was relevant to Fisk's claimed damages for loss of consortium; it rebutted Fisk's testimony concerning the value of Lindsey's support, companionship and care. See, e.g., Quinonez v. Andersen, 144 Ariz. 193, 198 (App. 1984) (domestic violence and other bad acts evidence admitted to rebut surviving spouse's claimed damages in wrongful death case); Udemba v. Nicoli, 237 F.3d 8, 14-16 (1st Cir. 2001) (past act of domestic violence admissible to show lack of damages); Fletcher v. City of New York, 54 F. Supp. 2d 328, 334 (S.D.N.Y. 1999) (past drug use admissible to show lack of damages). And the superior court mitigated any prejudice by instructing the jury to consider the evidence only for that purpose.

In addition to the financial consultant's unimpeached testimony that the present value of decedent's potential future income was $237,300, uncontradicted evidence was also presented regarding the decedent's close relationships with his family members. This case is not comparable to Quinonez v. Andersen, 144 Ariz. 193, 696 P.2d 1342 (App. 1984), which the dissent cites because our court affirmed an award of no damages to the husband of the deceased. In Quinonez, the court affirmed the $0 award because "under all of the circumstances, the jury may have concluded that all that Mr. Quinonez lost was a punching bag and a just and fair award for this loss was zero."

Once the underlying tort is established, the employer may be liable "not because of the relation of the parties, but because the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment." Quinonez for & on Behalf of Quinonez v. Andersen, 696 P.2d 1342, 1346 (Ariz. Ct. App. 1984) (quoting Restatement (Second) of Agency § 213, cmt. d (1952)). Thus, for a negligent hiring claim to lie, the employer must have known or had some reason to know of the employee's incompetence before hiring the employee.

¶20 Ignoring Lewis, which this Court has never overturned, Roaf cites a line of court of appeals decisions that are distinguishable from this case because they involved claims for separate, punitive damages. See Quinonez ex rel. Quinonez v. Andersen, 144 Ariz. 193, 696 P.2d 1342 (App. 1984). In Quinonez, a semi-truck driver struck a woman’s vehicle and killed her; her widower subsequently claimed the driver’s employer was liable both vicariously and for negligent entrustment.

Additionally, multiple subsequent cases decided by the Arizona Court of Appeals have held that the holding in Lewis—that negligent hiring and supervision is not an independent ground of actionable negligence against the employer—is limited. See Quinonez in re Quinonez v. Andersen, 696 P.2d 1342 (Ariz. Ct. App. 1984); Pruitt v. Pavelin, 685 P.2d 1347 (Ariz. Ct. App. 1984); Kassman v. Busfield Enterprises, Inc., 639 P.2d 353 (Ariz. Ct. App. 1981) (recognizing negligent hiring, training, and supervision as a separate cause of action against an employer).Brill v. Lawrence Transp. Co., No. CV-17-01766-PHX-JJT, 2018 WL 6696815, at *2 (D. Ariz. Dec. 20, 2018); see also Salazar v. Flores, No. CV-16-08201-PCT-SPL, 2019 WL 1254661, at *2 (D. Ariz. Mar. 18, 2019) (holding—consistent with Brill—that "[b]ecause the Court finds that Quinonez applies, Plaintiff is permitted to bring both vicarious liability and direct negligence claims under Arizona law").

. If the threshold tort finding is satisfied, the employer may be liable “not because of the relation of the parties, but because the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment.” Quinonez for & on Behalf of Quinonez v. Andersen, 696 P.2d 1342, 1346 (Ariz.Ct.App. 1984).

. If the threshold tort finding is satisfied, the employer may be liable “not because of the relation of the parties, but because the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment.” Quinonez for & on Behalf of Quinonez v. Andersen, 696 P.2d 1342, 1346 (Ariz.Ct.App. 1984).

. Similarly, the employer may be liable for negligent hiring “not because of the relation of the parties, but because the employer antecedently had reason to believe that an undue risk of harm would exist because of the employment.” Contreras v. Brown, No. CV-17-08217-PCT-JAT, 2019 WL 1980837, at *4 (D. Ariz. May 3, 2019) (quoting Quinonez in re Quinonez v. Andersen, 696 P.2d 1342 (Ariz.Ct.App. 1984)). “Thus, for a negligent hiring claim to lie, the employer must have known or had some reason to know of the employee's incompetence before hiring the employee.” Id. (citation omitted)