In a win for car and truck rental companies, a panel of the Connecticut Appellate Court held in Liam Stanford v. Clayton Nogiec, 233 Conn. App. 862 (2025), that a rental company's duty to investigate a prospective renter extends only to physical inspection of the renter's driver's license to confirm it is valid and unexpired. Unless the renter shows signs of unfitness to operate a motor vehicle, a rental company has no further duty to investigate a driver's background or driving record.
In Stanford, defendant Clayton Nogiec rented a car from Enterprise. Before renting the motor vehicle to Nogiec, an employee of Enterprise confirmed that his license was facially valid and unexpired. The employee also observed Nogiec and concluded that he did not demonstrate any signs of unfitness to operate the vehicle.
Enterprise and its employee were unaware that Nogiec was prohibited from operating a vehicle that did not have an ignition interlock device installed, a device intended to ensure Nogiec's sobriety while operating a vehicle. Nogiec struck the plaintiff while driving the rental vehicle. Police officers conducted a field sobriety test following the accident, which Nogiec failed.
At summary judgment, Enterprise argued that Stanford's negligent entrustment claim against it should be dismissed because, under the common law and Connecticut General Statute 14-153, Enterprise only had a duty to inspect Nogiec's physical license to confirm it was valid and unexpired, which it indisputably did. It had no further duty to search any electronic databases to determine whether Nogiec's license was subject to any limitations or restrictions.
The trial court agreed with Enterprise and granted summary judgment. A three-judge panel of the Connecticut Appellate Court affirmed. The Appellate Court interpreted the straightforward language of Section 14-153, which only required a rental company to physically inspect the license. As to any common law duty, the Appellate Court held that, under Connecticut law, "whether a car rental company may be held liable for negligent entrustment of a motor vehicle does not depend on whether the company could have taken affirmative steps to learn about the renter's incompetence; rather, it depends on whether readily apparent facts gave the company a reason to suspect that the renter was incompetent to operate a motor vehicle." 233 Conn. App. at 884.
With this decision, Connecticut aligns itself with seven other states and the District of Columbia that have held a rental company's common law duty does not extend beyond physical inspection of the driver's license. Those states are California, Florida, Louisiana, Massachusetts, Missouri, Texas and Washington. No appellate court in any state has imposed a broader duty under state common law.
Implications and Practical Considerations
The Connecticut Appellate Court's decision has important implications for rental businesses in Connecticut and across the country.
For rental companies facing entrustment claims in California, Connecticut, the District of Columbia, Florida, Louisiana, Massachusetts, Missouri, Texas and Washington, there are legal challenges to consider through either a motion to dismiss or summary judgment motion.
In all other jurisdictions, there will be case-specific strategic considerations for any legal challenge to an entrustment claim based on a lack of a state law duty. But in any case where such a challenge is brought, this decision shows a trend toward a correct recognition of the rental company's duty and should be cited in support of any dispositive motion asking a court to similarly rule that a rental company does not have a duty to investigate the background of a rental customer who presents a valid license and is not visibly impaired.
The plaintiff in Stanford will have an opportunity to petition the Connecticut Supreme Court for review of the Connecticut Appellate Court's decision.
For More Information
If you have any questions about this Alert, please contact Harry M. Byrne, Alyson Walker Lotman, Ryan F. Monahan, any of the attorneys in our Transportation, Automotive and Logistics Industry Group or the attorney in the firm with whom you are regularly in contact.
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