§ 51-2-4 pertains to an employer's liability for the negligence of an independent contractor and thus is inapplicable to cases which involve intentional torts. When is the employer liable?Georgia, like many other states, has statutes designed to shield certain entities from tort liability under specific circumstances. The Georgia Tort Claims Act (GTCA) requires a 12-month written notice when filing a personal injury case against a government agency. If multiple lawsuits are filed as a result of the same occurrence, the limit of liability against the Fund is the amount specified on the Declarations Page. In the late nineteenth century, defenses which had essentially immunized employers from liability to injured workers began to erode. As a result, direct negligence claims are no longer subject to summary judgment when the employer admits vicarious liability. Employers now face increased exposure to liability on independent theories of negligent hiring, training, entrustment, and retention. In return, the employer is shielded from tort liability for these injuries. The. Court of Appeals held that such claims were exempted from possible coverage under the.