no uniform jury instructions for successor tortfeasor cases, and there was very little case law on the subject, which was in flux, we remanded for a new trial. Id. ¶ 38. {34} Here, unlike in Payne, while no uniform jury instruction on negligent hiring existed at the time of trial, see UJI 13-1647 NMRA Use Note (adopted December 3, 2010), well-established case law laying out the elements of negligent hiring did exist. See Valdez v. Warner, 106 N.M. 305, 307-08, 742 P.2d 517, 519-20 (Ct. App. 1987) (describing the standard for negligent hiring); see also Spencer v. Health Force, Inc., 2005-NMSC-002, ¶¶ 10, 22-24, 137 N.M. 64, 107 P.3d 504 (discussing causation in the negligent hiring context); Pittard v. Four Seasons Motor Inn, Inc., 101 N.M. 723, 729, 688 P.2d 333, 339 (Ct. App. 1984) (<HOLDING>). Because Meteor invited jury instruction error
holding that negligent entrustment claim is unnecessary prejudicial and redundant when defendant employer admits that the employee was acting within the scope of employment recognizing torts of negligent hiring supervision and retention recognizing that a showing of scope of employment is unnecessary under a negligent hiring theory recognizing as viable actions in tort negligent hiring and negligent retention holding that for a plaintiff to recover on claim of negligent hiring the negligent hiring of the employee must have been the proximate cause of the injury at issue