It is possible to view Curry's actions either completely independently, or as a mode of performing an authorized act.

By a special authorized Act of Congress, the medal was presented to Byrd and Bennett (see above).

(2) acts which are not authorized by the employer, but are so connected to authorized acts that they may be considered "modes" of acts authorized by the employer.

The law imposes upon an agent the duty of loyalty to the principal and upon the principal the duty to protect the agent against loss or damage incurred while carrying out authorized acts.

For an act to be considered within the course of employment it must either be authorized or be so connected with an authorized act that it can be considered a mode, though an improper mode, of performing it.

"I trust and hope that these offensive activities are not the authorized acts of your organization's employees and agents," Mr. Fernandez wrote, requesting a reply from Microsoft with assurances that its promotional staff and agents would be directed "to avoid such illegal conduct."