of the Charitable Immunity Act beyond acts based upon negligence. The Court did discuss in dictum the dissent’s view that the intentional nature of the underlying conduct removed the entire incident from the Charitable Immunity Act’s protections. The majority rejected that view, finding that, ordinarily, employers are not held liable for the intentional acts of employees, since they fall outside the scope of employment. If the dissent’s position were adopted, the Court reasoned, “[t]hat would make the church, protected in the past by the common law immunity and now by statutory immunity, more vulnerable than private entities protected by neither common law nor statutory immunity.” Schultz, supra, 95 N.J. at 535, 472 A.2d 531. But see Frugis, supra, 177 N.J. at 268-74, 827 A.2d 1040 (<HOLDING>); Lehmann v. Toys ‘R’ Us, Inc., 132 N.J. 587,
holding that it is impermissible to dismiss a teacher for openly criticizing the board of education on its allocation of school funds between athletics and education and its methods of informing taxpayers about the need for additional revenue holding that the board of education violated a school teachers first amendment rights by dismissing him because he had criticized the board in a letter to the local newspaper holding principal liable to third party for tort of agent despite lack of privity between principal and third party holding a board of education independently liable despite the intentional nature of the conduct of its employee a school principal holding that members of the board of trustees of an elementary school had standing to challenge the actions of the county board of education because they suffered an actual injury when the county board nullified their unanimous vote to reject a candidate for principal of the elementary school