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Keywords

lawsuitliabilitystatuteappealsummary judgmentleasevicarious liability
liabilitystatutetrialmotionsummary judgmentleasevicarious liabilitymotion for summary judgment

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Vargas v. Enterprise Leasing Co., 993 So.2d 614, 33 Fla. L. Weekly D2574

Facts

Rafael Vargas was involved in a collision with a rental vehicle leased by Elizabeth Price from Enterprise Leasing Company. Vargas filed a personal injury lawsuit against Price, her son Jimmy Middleton, and Enterprise, claiming vicarious liability under Florida's statute. Enterprise contended it had no liability under the Graves Amendment, which preempted state laws imposing vicarious liability on rental car companies. The circuit court granted summary judgment to Enterprise, leading Vargas to appeal.

Enterprise Leasing Company leased a motor vehicle to Elizabeth Price for a period of less than one year. On February 12, 2006, Mrs. Price's son, Jimmy Middleton, crashed the rental vehicle into the rear end of a car driven by Rafael Vargas.

Issue

Whether the Graves Amendment preempted Florida's vicarious liability statute for rental car companies, specifically section 324.021(9)(b) 2.

We hold that the Florida statute has been preempted and affirm the judgment of the trial court.

Rule

The Graves Amendment, 49 U.S.C. § 30106, preempts state laws imposing vicarious liability on rental car companies unless the state law is a financial responsibility law or liability insurance requirement.

Section 324.021(9)(b) 2 comes within the preemption language of 49 U.S.C. § 30106(a), since it is a state law that imposes liability upon a lessor 'by reason of being the owner of' a motor vehicle.

Analysis

The court analyzed the language of the Graves Amendment and determined that Florida's section 324.021(9)(b) 2 imposed liability on rental car companies based solely on their ownership of the vehicle, which fell under the preemption of the Graves Amendment. The court concluded that the Florida statute did not qualify as a financial responsibility law because it did not require rental companies to maintain insurance or provide proof of financial responsibility as a condition of operating a vehicle.

The 'Florida legislature's endorsement of and limitations on' the vicarious liability imposed under the dangerous instrumentality doctrine is not a 'financial responsibility' requirement.

Conclusion

The court affirmed the circuit court's ruling, concluding that the Graves Amendment preempted Florida's vicarious liability statute for rental car companies.

For these reasons, we join with those courts that have concluded that the Graves Amendment preempts section 324.021(9)(b) 2.

Who won?

Enterprise Leasing Company prevailed in the case because the court found that the Graves Amendment preempted the Florida statute imposing vicarious liability on rental car companies.

The circuit court granted Enterprise's motion for summary judgment, ruling that the Graves Amendment preempted section 324.021(9)(b) 2, which it determined was a vicarious liability provision and not a financial responsibility statute.

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