How have courts treated vicarious liability claims against a government employee who is not identified as an employee?

Hayes v. County of San Diego (2013) 57 Cal.4th 622, 639, fn. 1, 160 Cal.Rptr.3d 684, 305 P.3d 252 [unless the employee is identified, the trier of fact will not be able to determine if the elements needed to assert vicarious liability have been proved].)

c. Government Code section 820.2

Government Code section 820.2 states, [e]xcept as otherwise provided by statute, a public employee is not liable for an injury resulting from his act or omission where the act or omission was the result of the exercise of the discretion vested in him, whether or not such discretion be abused. Government Code section 815.2, subdivision (b), extends that discretionary act immunity to the public entity whose employee's conduct is at issue, Except as otherwise provided by statute, a public entity is not liable for an injury resulting from an act or omission of an employee of the public entity where the employee is immune from liability. These statutes provide immunity for basic policy decisions by government officials, but not for the ministerial implementation of that basic policy. (Johnson v. State of California (1968) 69 Cal.2d 782, 796, 73 Cal.Rptr. 240, 447 P.2d 352.)

[240 Cal.App.4th 1339]