Jason Puerini v. Jeanne LaPierre

Citations

• 208 A.3d 1157

Syllabus

This appeal arose out of litigation over whether the owner-lessor of a motor vehicle was vicariously liable for the alleged negligence of the driver-lessee in a roadway collision resulting in injuries to plaintiff Jason Puerini. A hearing justice of the Superior Court granted the owner-lessor's motion for summary judgment. On appeal, the plaintiffs argued that the owner-lessor of the motor vehicle was not entitled to summary judgment because it did not qualify for protection from the federal Graves Amendment, 49 U.S.C. § 30106. The Supreme Court first addressed a question of first impression in this jurisdiction—whether the Graves Amendment preempts our state laws allowing a party injured in a motor vehicle accident to recover from the title owner of the vehicle through the owner's vicarious liability for the negligence of the driver. The Supreme Court held that the Graves Amendment conflicts with G.L. 1956 § 31-34-4 and therefore preempts application of this state statute authorizing vicarious liability for the title owner of a motor vehicle when the vehicle operator's negligence causes injury. The Supreme Court also addressed G.L. 1956 § 31-33-6, holding that, to the extent that this statute makes business entities potentially vicariously liable for failure to comply with financial responsibility or liability insurance requirements, this statute is not preempted because it specifically falls within the § 30106(b)(2) savings clause of the Graves Amendment. In addition, the Supreme Court held that the Motor Vehicle Reparation Act, G.L. 1956 chapter 47 of title 31, is not preempted by the Graves Amendment because the consequences for automobile dealers for failure to comply with the requirements of this statute do not include vicarious liability for the alleged negligence of automobile drivers. The Supreme Court also engaged in a de novo review of the evidence HLT submitted in support of its motion for summary judgment, as well as the evidence plaintiffs submitted in