Enterprise Rent-A-Car of L.A. v. Super. Ct.
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After D.G. was injured in a car accident involving a rental car driven by I.M. H.A. rented the car involved in the accident from Enterprise Rent-A-Car Company of Los Angeles (ERAC-LA). I.M. was listed as an additional authorized driver in the rental agreement between H.A. and ERAC-LA. At the time of rental, I.M. presented ERAC-LA with a facially valid driver’s license issued by Kyrgyzstan and a local California address on the rental paperwork. D.G. sued ERAC-LA, I.M., and EAN Holding, LLC (EAN) for negligence. Specifically, D.G. alleged ERAC-LA negligently entrusted I.M. with the rental vehicle, and therefore proximately caused her injuries. ERAC-LA filed a petition for writ of mandate in this court to reverse the trial court’s order denying its motion for summary judgment.
The Second Appellate District issued a writ of mandate directing respondent court to vacate its May 24, 2022 and July 29, 2022 orders denying ERAC-LA’s motion for summary judgment and enter a new order granting the motion. The court held that requiring a rental car agency to investigate whether a prospective renter who presents a facially valid foreign driver’s license is still a resident of that jurisdiction at the time of rental goes beyond the scope of duties prescribed by the Legislature. The court further concluded that D.G. failed to carry her burden to demonstrate a triable issue of material fact exists regarding ERAC-LA’s compliance with section 14608, subdivision (a)(2).
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