13 . See Gutierrez de Martinez v. Drug Enforcement Admin., 111 F.3d 1148, 1158 (4th Cir. 1997) (applying Virginia law and concluding that "drinking alcohol by itself does not remove the employee from the scope of his employment"); Stephenson, 771 F.2d at 1107-08 ("[The fact that [the employee] was intoxicated when driving does not mean that he was acting outside the scope of his employment, but only that he failed to use reasonable care under the circumstances."). 14 . Ortiz v. Clinton, 187 Ariz. 294, 928 P.2d 718, 723 (App.1996); accord Stephenson, 771 F.2d at 1108 ("The [employer] cannot insulate itself from. lability ... by promulgating regulations prohibiting employees from drinking and driving."); Pyne v. Witmer, 159 Ill.App.3d 254, 111 Ill.Dec. 452, 512 N.E.2d 993, 999 (1987) (<HOLDING>). 15 . 791 P.2d 344, 348 (Alaska 1990),
holding that county liability under  1983 cannot rest on a theory of respondeat superior holding that employees defamatory statements made at work about matters relating to work were within the scope of their employment for purposes of respondeat superior and recognizing that californias respondeat superior doctrine imposes a broad rule of liability on employers holding that employees violation of his employers policy against drinking on the job does not preclude liability under respondeat superior holding that a plaintiffs direct negligence claims against an employer are not precluded by the employers admission of respondeat superior liability recognizing respondeat superior liability