Garcia v. Steele
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The Supreme Judicial Court held that, under the circumstances of the underlying case, the Graves Amendment, 49 U.S.C. 30106, protected an automobile dealership from being held vicariously liable for the tortious conduct of the driver of its courtesy vehicle.
An automobile dealership based in New Jersey provided a courtesy vehicle to a customer while it serviced the customer's vehicle in its automobile service center. Contrary to the terms of the courtesy vehicle agreements, the customer drove the vehicle beyond the permitted radius of travel and into the Commonwealth, where the vehicle struck one of the plaintiffs, causing serious injuries. Plaintiffs brought a negligence action against the dealership and the customer. The superior court granted summary judgment for Defendants, concluding that the dealership, as the owner of the courtesy vehicle, was presumptively vicariously liable for the injuries caused by the customer's wife. The Supreme Judicial Court affirmed the judgment for the dealership and vacated the judgment for the customer, holding (1) the Graves Amendment protected the dealership from liability in this case; and (2) there was a dispute of material fact as to the negligent entrustment claim against the customer.
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