In Gallagher v. Tucson Unified School District, No. 2 CA-CV 2014-0124, 2015 WL 2221657 (Ariz. App. May 12, 2015), the Arizona Court of Appeals held that TUSD was entitled to absolute immunity under A.R.S. § 12-820.05. The court held that the requested damages (“anxiety, reasonable expenses for medical intervention or other professional assistance, loss of consortium, loss of enjoyment of life and breach of privacy experienced and reasonably probable to experience in the future”) constituted “losses” for which the statute provided immunity. The court also held that the statute applies to claims for both vicarious and direct liability claims. Finally, the court held that the statute’s exception (“unless the public entity knew of the public employee’s propensity for that action”) required proof that the entity had actual knowledge of the criminal propensity; constructive knowledge is not enough.