Page:Echeverry v. Jazz Casino Co., LLC (20-30038) Opinion.pdf/6

 insured. AWR provided a certificate of insurance to the Casino at about the time it began work on the project, February 6–7, 2017, but the identified policy had expired in October 2016.

The Casino argues that none of this evidence is relevant. The “F” rating from the BBB, the Casino points out, was not necessarily a result of safety concerns and could not have put the Casino on notice of safety risks in hiring AWR. At trial, the jury heard that a business’s failure to respond to consumer complaints against that business was the most common reason for an “F” rating. There is no evidence that the Casino knew what earned a business an “F” rating when it hired AWR, and the Casino denied knowledge of the rating anyway. The jury, however, could have found that the Casino at least should have known about the rating when hiring AWR. We find that the rating itself is not strong evidence of AWR’s ability to complete the project safely or competently, but it is some evidence to support that the Casino should have investigated further before contracting with the company. The BBB rating may reflect more on the Casino’s failure to investigate adequately before hiring AWR than it reflects on the competency of AWR. The jury, however, is permitted to make inferences from the evidence. Regardless, the BBB rating is not the only evidence Echeverry presented for the negligent-hiring theory.

Other evidence was that AWR’s certificate of insurance showed an expired insurance policy. The Casino’s internal policies required that it hire only contractors who were insured. There was evidence at trial that the Casino hired AWR through a purchase request rather than a more formal contract in order to accelerate the process. Under usual circumstances, the Casino would delay issuing a purchase order until it had received a valid certificate of insurance from the vendor, but that did not occur here. The Casino argues that this evidence does not support negligent hiring because it did not know that AWR was uninsured until after it hired AWR and,