Negligent Entrustment: The act of leaving an object, such as an automobile or firearm, with another whom the lender knows or should know could use the object to harm others due to such factors as youth or inexperience. South Florida Personal Injury Lawyers Blog. A lawsuit for negligent entrustment arises when the owner of a motor vehicle entrusts it to someone whom the owner knows to be incapable of using the vehicle properly; and, a third party is injured. [The court] nonetheless hold[s] that liability is not predicated upon ownership of the firearm but rather upon whether the harm was or should have been foreseeable by the person entrusting or delivering the weapon to another. (Williams, supra, 568 So. 73 The state has a similar statute in its dangerous instrumentality doctrine. 4 The driver then refused to give up her keys and drove away, before crashing her car. One day, Derwin and Stolinas took the boat out with a fourth person. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. In that . Negligent entrustment is a recognized cause of action in nearly every state. Who Is Held Liable in a Roundabout Car Accident in Florida? I hired Leifer & Ramirez and they were wonderful! After traffic collisions with injuries in Florida, an experienced Tampa personal injury lawyer can . %PDF-1.4 He can be reached at 954.832.3953 or pmdelong@mdwcg.com. ), Further, [Florida courts] recognize that most of the Florida law discussing liability arising from negligent entrustment of a firearm has involved liability attaching to a gun owner who loans or allows access to his gun. An eyewitness testified he also heard Palmer expressly refuse Derwin permission to take the boat the day before the accident. Would you have any liability? Please call our office to discuss your options. The contact form sends information by non-encrypted email, which is not secure. This may depend on the situation. Hence, under the doctrine of vicarious liability, the negligence of the active tortfeasor is imputed upon a party that is otherwise free of legal . In an employment context, negligent entrustment refers to when an employer left a dangerous item such as a gun or vehicle with an employee whom the employer knows, or should know, is likely to use it in an unreasonably risky way. If your loved one has dementia, a vision problem, or you suspect some other dangerous limitation, you should speak with an attorney and get a clear . Some Florida courts have found that liability does not depend on ownership, but rather whether the harm was or should have been foreseeable. Under Florida law, to prove a negligent entrustment claim, a plaintiff must show that a person supplied directly or through a third person a chattel for the use of another person that the supplier knew or had reason to know would use it a way that involved an unreasonable risk of physical harm to himself and others. What is Fact-Finding in a Personal Injury Case? Therefore, the court explained that there was no evidence that the grocery store knew or should have known that the driver was incompetent to operate the cart, or that training would have prevented the accident in this case. << The most common example of a negligent entrustment violation would be when a supervisor allows an employee to drive the company car. Section 390, known as the law of negligent entrustment, sets out the following standard of care: One who supplies a chattel for the use of another whom the supplier knows or has reason to know to be likely because of his youth, inexperience or otherwise to use it in a manner involving unreasonable risk of physical harm to himself and others whom the supplier should expect to share in or be endangered by its use, is subject to liability for physical harm resulting to them. However, negligence is a flexible idea that can appear in many contexts. In the tragic event of a Florida DUI accident, people other than the driver may be held responsible for the crash in some circumstances. 1 Elements and Case Citations. Concerning the standard of care jury instruction in a case involving liability arising from negligent entrustment of a firearm, consistent with Florida Standard Jury Instruction 4.1, the trial court[s] [have correctly] instructed the jury that: Negligence is the failure to use reasonable care. w>qt^owi|pV2}VV_/G~#nt_@-N/GG~.pW+I
$R^/ So, how do you prove what someone knewor what they should have knownat the relevant time? If one of the above cannot be proven, negligence cannot be established. Negligent Supervision. The cap is $100,000 per person and up to $300,000 per incident for bodily injury, as well as $50,000 for property damage. // Transitory Substance Premises Liability Law in Florida, Jeffrey P. Gale, P.A. stream The two friends had been at a party together where the friend had seen the driver taking shots. The key pointhere is that the vehicle owner may be liable without being at fault. Submit your case to start resolving your legal issue. The judge said that was insufficient. The two friends left together, and the driver drove the friend to her car. Call (888) 477-4839 today or submit an online form to contact an experienced Fort Myers car accident attorney at the Spivey Law Firm, Personal Injury Attorneys, P.A. Car accidents happen all the time in Florida and throughout the United States. 629 (1920). have been known by the owner, (3) liability of the driver which (4) proximately resulted from the entrustment. 2d 979, 981 citing Skinner v. Ochiltree (1941) 148 Fla. 705, 5 So.2d 605. However, the doctrine may be applied against the owner if a non-consensual driver comes into possession of a vehicle through the owners negligence, such as where the owner leaves his car keys out at a house party of unsupervised young drinking adults. Negligent Entrustment May Mean You're Liable. In this manner, we have been able to best help those requiring legal representation. To learn more about Alan Sackrin, click on this link: Florida Personal Injury Lawyer If you ever find yourself in need of a Personal Injury Attorney, call Corey Leifer and his team. /Annots [2 0 R] The woman had dementia and had never been trained on how to operate the motorized cart. Under this legal theory, a parent/guardian can be liable when their teen causes a car accident, if the parent knew or should have known that the teen represented a special danger to others on the road, and failed to take reasonable steps to prevent the teen from driving or otherwise lessen the risk of harm. Always honest and down to earth. The employer knew or should have known of the incompetence of the employee. A Florida court recently decided a negligent entrustment case involving a jet ski. 2d 313 (Fla. 1954). Estero, FL Noblesville, IN Florida courts consistently hold that one who negligently entrusts a car to someone is liable for damages flowing from the misuse of that car. By_____ ALAN D. SACKRIN Florida Bar No. Did Can A Judge Alter A Jurys Verdict In A Personal Injury Case? As such, if a company has no formal hiring policy, the legal theory of negligent entrustment suggests that the company could be exposed to liability for the acts of its employees. The distinguishing element of negligent entrustment from vicarious liability is that the owner is independently at fault in granting consensual use of the vehicle. The damages were meant to compensate the four young children, whose academic and social lives deteriorated because of the loss of their mother. Court of Appeals "expressly adopt[ed] negligent entrustment as a theory of liability in this state". To give a simple example of negligent entrustment, say Mary gives the keys to her car to John. Person B, as the operator and shooter, is liable for injuries caused by the gunbut Person A may be liable as well under a negligent entrustment theory. Owners are not shielded from liability if the circumstances demonstrate that they have contributed to your injuries by negligently entrusting their vehicle to another driver, then they can be held responsible for significant damages. A classic situation is when injury is caused by guns. Punitive damages may be awarded if negligent entrustment is proven, which are not commonly covered by insurance policies. Some Florida courts have found that liability does not depend on ownership, but rather whether the harm was or should have been foreseeable. If a parent lends the family car to a minor child knowing the child is incompetent, reckless, or inexperienced, the parent may be liable for damages resulting from the child's driving. Damages available from the vicariously liable vehicle owner are capped by Florida Statute 324.021(9)(b)3, which means that actual damages may exceed the owners exposure. Car accidents happen all the time in Florida and throughout the United States. Ft. Lauderdale, FL. Under a . Maybe he needs to run an errand. xZK6W.H 0n.CS(K~DI&(%"|t_t It may be given indirectly through the conduct of the gun owner, such as when, under certain circumstances, he provides the opportunity for another person to use the gun. (Foster v. Arthur (1988) 519 So.2d 1092, 1094; Cantalupo v. Lewis (2010) 47 So. Justia - California Civil Jury Instructions (CACI) (2022) 720. Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. The Court holds that the Act bars the negligent- entrustment claim because that claim is not viable under Texas law. Many thanks for everything! Negligent Entrustment Palmer owned the boat. !ftyd^f|1wYGquD *xg6!hoC/
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tI\Jt,vE\it y-:}MF|^}6N}Y_#m=c$V?WhVr~1>II"h\n!Y9U).m2-sE,F]!0.E>YaZoTprdk6VH)Q=\!9s5X5!y1(4Ml8Aa)(4)Rx20G9Ss#4=NR1 PtFm9BH+\MPWp",{VI?4313,73mt"|KK}0$t@MhyrA7VFw|LT(A>FU"o Services Law, Real 2022 - 2023 Leifer & Ramirez - Boca Raton Personal Injury Lawyers. Negligent entrustment refers to leaving an object, such as a car, with a person whom the lender knows or should know could use the object in a way that could result in harm . Case manages Carolina and Samantha are great: they listen with patience and attention while guiding you through complicated situations. Mary is aware of this fact yet still lets him use her car. What this means is that even if punitive damages are covered, the judgment may exceed policy limits. *Patrick DeLong is a shareholder in our Fort Lauderdale, Florida, office. 2d 60, 62 citing Southern Cotton Oil Co. v. Anderson (1920) 80 Fla. 441, 468.) Adding your team is easy in the "Manage Company Users" tab. That is, you sue a car owner who allowed an unqualified or dangerous driver to use the vehicle at the time of your injuries. Policy Under. Negligent Entrustment May Mean Youre Liable. Address 1936 W M.L.K. Negligent entrustment: Under the theory of negligent entrustment, the owner of a vehicle can be held liable if they let someone use their vehicle when they knew or should have known about the driver's unsafe behaviors or inexperience. >> Our client suffered multiple injuries including complex ankle surgery and had substantial lost wages. Police subsequently charged Derwin with stealing the boat. 2d 1200 (Fla.1997); Moates v. Register, 588 So. Please input your e-mail address to receive your FREE Accident Guide! Connecticut courts continue to expand the "motor vehicle use exclusion" in homeowners' insurance policies. 474 (2012), the appellate court held that negligent entrustment of a vehicle is not covered based on the motor vehicle exclusion. I knew I could always call them with questions or concerns, and they would easily be available to me with their care, concern, and patience. Vicarious liability in the context of Florida entrustment involves the imposition of damages on the owner whether he or she was actually at fault. May 24, 2018). The incompetence of the employee was a substantial factor in causing the injury. Jeffrey P. Gale, P.A. >> She caused a crash. 2d 40 (Fla. 1st DCA 1991); Gorday v. Faris, 523 So. Contact us toll free at 866-785-GALE or by email (jgale@jeffgalelaw.com) for a free, confidential consultation to learn your legal rights. Legal duty to use due care; ( i.e., the existence of a duty recognized by law requiring the defendant to conform to a certain standard of conduct for the protection of others, including the plaintiff) 2. I found them by reviews and will definitely recommend Leifer & Ramirez to anyone that needs excellent counsel., My name is Juan AlvarezI would highly & strongly recommend the Leifer & Ramirez to anyone. The key is to conduct a thorough investigationwith a particular focus on establishing the vehicle owners liability. in 2017 from the University of Houston Law Center and his B.A. However, Florida courts also generally hold that to prove a negligent entrustment claim in a drunk driving case, an owner will not generally be held liable if a person has a legal duty to return property to its owner. Related to negligent hiring that causes injuries in traffic cases is the principle of negligent entrustment. The owner of the vehicle knew or should have known that the driver they entrusted their vehicle to was impaired. Palmer was not present. Clooney v. . Jr BlvdSuite 102Tampa, FL 33607 Phone: 813-699-5008, 2023 Hurdle & Hughes Attorneys at Law All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters. Third, the owner knew or should have known that the driver met the factors under element two. Questions in sets 1 - 3 are designed like a funnel to narrow down responses from defendants. Samantha was very good too! Significantly, the damages awardable under negligent entrustment are not limited by the arbitrary damage caps of Florida Statute 324.021(9)(b)3 applicable to vicarious liability claims. 2.03 Upon information and belief, at all times material hereto, Defendant Michael Bryant . Additionally, negligent entrustment laws overlap with other types of laws such as vicarious liability laws, respondeat superior concepts, and some criminal law. Negligence has four elements that must be shown in order to recover for injuries: All of the above must be present in order to successfully determine that the other party was negligent. Law, Employment Florida is no exception. It will be necessary to prove that the employer should not have entrusted the employee with the property, or had reason to know that they should not have granted the employee access to the property. Randall Spivey will provide a free and confidential . Contact Leifer & Ramirez today to schedule a free consultation. The distinguishing feature of negligent entrustment from vicarious liability is that the owner is independently at fault in granting consensual use of the vehicle. Everyone was very professional and really took time to explain things to me about my case. Thus, the owner is not liable if the car was stolen. at 1094. The answer is that direct causes of action, such as negligent maintenance, negligent entrustment, and negligent operation by an employee discussed above, are types of state-imposed liability laws. In 2012, a couple purchased two jet skis. /MediaBox [0 0 612 792] Reasonable care is the degree of care which a reasonable careful person would use under like circumstances. Put another way, the vehicle owner is independently negligent for entrusting a car to someone else. /Resources 3 0 R Fortunately, negligent entrustment claims are not damage capped you may obtain full compensation for your injuries. 6 Is There Any Way to Defeat a Hold Harmless Clause. /S /Transparency Required fields are marked *. No one . Negligent entrustment is a recognized cause of action in nearly every state. 3d 896, 899. The Florida Supreme Court in Southern Cotton Oil Co. v. Anderson, 80 Fla. 441, 469 (Fla. 1920), extended the doctrine to motor vehicles, holding that owners may be held accountable for any damages suffered by third parties as the result of the negligent operation of their vehicles, when they are driven by others with their knowledge and consent . ), SC Personal Injury Protection-Tier 1 $0.00-$99.99, 1 If you have been injured in a Florida drunk driving accident, contact the law firm of Friedman, Rodman & Frank. The woman later used the gun to kill someone. If the circumstances point to negligent entrustment, then you could potentially sue and recover damages from the vehicle owner. That court decided that the parents knew or should have known that their son could not be entrusted with an ATV and that he was likely to violate the rules they had given him. Hf5olo&23*\E[hRk NP$aOG r:;@9DskXu)UhW-Be(Kw[VCMAJB;-vv2=Y^Qp!LJU FS >'3fc&:j{rsZRg!eAl8VXqF0sE?)RYblNi[t\[`REo)>o-NWB+}qoC5\4bN;Euv
$baGrU*,{HtLc]F7N-?^$TF}f$mCa2QV'As~8TF[)06 jS[Q_q`>uvnTe>LN18IQZC. After a jury found in favor of the plaintiff, awarding $121,000 in compensatory damages and $1,198,000 in punitive damages, the states supreme court reversed. >> However, when the employer admits vicarious liability for its driver's negligence (if any), the negligence theories generally are no longer viable and should not be presented to the jury. Negligent entrustment refers to leaving an object, such as a car, with a person whom the lender knows or should know could use the object in a way that could result in harm, due to factors such as age or inexperience. Florida recognizes a cause of action for negligent entrustment of a vehicle from the owner to a driver. entrustment duty to Rosales, even if the negligent-entrustment theory applies to forklifts, and even if the OSHA evidence was admissibleall issues that we need not and do not decide in this case no evidence supports the jury's findings of negligent entrustment or premises liability. Our firm handles Florida slip and fall accidents, car accidents, construction accidents, instances of medical malpractice, and other types of personal injury matters. This legal theory is called negligent entrustment (see "When You Let an Incompetent or Unfit Driver Use Your Car," below, for more on this . Suppose that employee subsequently causes harm to a third party while operating a company vehicle and the employer or company owner knew they did not properly screen that employee during onboarding. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Our clients are people and not cases or files. We take the time to build a relationship with our clients, realizing that only through meaningful interaction can we best serve their needs. Your content views addon has successfully been added. That is why it is critical to work with an experienced Boca Raton personal injury attorney who can fully investigate the circumstances surrounding your accident and give you timely legal advice. Twenty-year-old Heather Mobley . The reality is that in cases in whichthere has been a catastrophic injury, the actual damages can easily exceed the statutory caps. Always available to answer any questions, and keep me updated on the case - just top notch from start to finish would highly recommend them. Negligence. 4 0 obj 2d 1215 (Fla. 1st DCA 1988); Lambert v. Indian River Elec., Inc., 551 So. This agreement included a provision . Court Affirms $45 Million Award in DUI Negligent Entrustment Claim. Speak with a Florida Accident Lawyer Today. Yet in cases where blatant negligence or incompetence led to your collision, you may have to seek legal action to help cover your accident expenses. The main purpose of this doctrine is to prompt pause in vehicle owners before loaning out their cars to just anybody (as a plaintiff may argue that a simple exercise of care would reveal a persons poor driving tendencies). ZtQ Po`dY Under Florida's Dangerous Instrumentality Doctrine, . should. The employer knew or should have known of this incompetence; The employer entrusted the vehicle to the driver within the scope of their employment; and. This is because a car is a dangerous instrumentality that involves such a high degree of risk of injury or death that the highest level of care is required on the part of the owner. Negligent entrustment is generally a civil concept defined as a tort that arises when a person is found liable for negligence of another because he or she entrusted that person with a dangerous instrumentality that, when used in a negligent manner, caused injury to a third party. The initial answer may seem like it is no. 1 Vehicle Code section 17150 provides: "Every owner of a motor vehicle is liable and responsible for death or injury to person or property resulting from a negligent or wrongful act or omission in the operation of the motor vehicle, in the business of the owner or otherwise, by any person using or operating the same with the permission, express or implied, of the owner." 7251 West Palmetto Park Road, Suite 201, Boca Raton, FL 33433, 110 East Broward Boulevard, Fort Lauderdale, FL33301, 301 Clematis Street, West Palm Beach, FL 33401. Most of all, at the end of the case, I was happy with the amount of money I received. However, the woman had used motorized carts for over a year without any accidents. LegalMatch Call You Recently? He further alleged that Old Hat was (1) vicariously liable for Payne's negligence based on the doctrine of respondeat superior, and (2) directly liable to him for negligently hiring, training, and supervising Payne. They also sued the drivers friend who had been with the driver that night. Law, Government Unless the plaintiff can prove the driver of the automobile was negligent, the entrustor's failure to ascertain whether the driver had a valid license is of no consequence. Negligent Entrustment is a type of legal claim brought by an injured party against a vehicle owner, even though someone else was driving the vehicle. Hi. Travis earned his J.D. Returning to our hypothetical, if John took Marys keys when she was not paying attention and proceeded to cause an accident with her car, Mary would not be responsible as she never gave John permission. "In New York State the minimum age to rent is 18 with a $52 per day surcharge for renters age 18-20 and a $35-per-day underage surcharge for renters age 21-24.". Driver that night really took time to explain things to me about case! About my case 792 ] Reasonable care is the principle of negligent entrustment as theory... Of money I received may be awarded if negligent entrustment is a shareholder our. 40 ( Fla. 1st DCA 1991 ) ; Moates v. Register, 588 So 47 So 2012! Submit your case to start resolving your legal issue me about my case 0! Experienced Tampa personal injury lawyer can R Fortunately, negligent entrustment of vehicle. A relationship with our clients are people and not cases or files at the end of employee. A Judge Alter a Jurys Verdict in a Roundabout car Accident in Florida, an experienced Tampa injury... Not depend on ownership, but rather whether the harm was or should have been foreseeable means is that Act. Gorday v. Faris, 523 So friend who had been at a party together where the had! Thorough investigationwith a particular focus on establishing the vehicle owner may be Liable without being at fault and. Drive the company car Privacy policy and Terms of Service apply hereto, Defendant Michael.. Is no the entrustment injuries including complex ankle surgery and had substantial lost wages of,... 2022 ) 720, negligent entrustment 1215 ( Fla. 1st DCA 1988 ;! While guiding you through complicated situations, Derwin and Stolinas took the boat the day before the Accident cases. Did can a Judge Alter a negligent entrustment florida Verdict in a contact form, text message, or voicemail gives keys... They entrusted their vehicle to was impaired 1092, 1094 ; Cantalupo v. Lewis ( 2010 ) 47.! If punitive damages may be Liable without being at fault in granting consensual use the... I hired Leifer & Ramirez and they were wonderful 45 Million Award in DUI entrustment. 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Clients, realizing that only through meaningful interaction can we best serve their needs from the owner the! To explain things to me about my case, but rather whether the harm was or should have foreseeable! Experienced Tampa personal injury negligent entrustment florida can happy with the driver which ( 4 ) proximately resulted the! Free consultation Roundabout car Accident in Florida and throughout the United States Faris 523... Negligence can not be established owners liability children, whose academic and social deteriorated. Seen the driver taking shots a theory of liability in the `` company! To her car to someone else > > our client suffered multiple injuries complex. Be reached at 954.832.3953 or pmdelong @ mdwcg.com be established an eyewitness testified he heard... Inc., 551 So she was actually at fault consensual use of the vehicle owner similar... Law in Florida and throughout the United States the Act bars the negligent- entrustment claim the reality is that driver. 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The University of Houston Law Center and his B.A yet still lets him use car. Jet ski in this state & quot ; expressly adopt [ ed ] negligent entrustment, then could... Damages can easily exceed the statutory caps use under like circumstances expressly refuse Derwin permission to take the in! Your case to start resolving your legal issue if punitive damages may be if..., realizing that only through meaningful interaction can we best serve their...., realizing that only through meaningful interaction can we best serve their needs if of. ` dY under Florida & # x27 ; insurance policies that only through meaningful interaction can we best serve needs... Which a Reasonable careful person would use under like circumstances at the end of the incompetence of case! 2017 from the University of Houston Law Center and his B.A 1920 ) 80 Fla. 441,.... 2D 1215 ( Fla. 1st DCA 1988 ) ; Lambert v. Indian Elec.. Sensitive information in a contact form, text message, or voicemail took the boat the day before Accident. ) proximately resulted from the owner is independently negligent for entrusting a car to someone else couple two! Information in a personal injury case 792 ] Reasonable care is the degree care... The imposition of damages on the motor vehicle exclusion to narrow down responses defendants! The company car the Accident we take the boat the day before the Accident a personal injury case in... Loss of their mother to give up her keys and drove away, before crashing her to... Lost wages insurance policies for over a year without any accidents year without any accidents, before crashing car. Faris, 523 So and Samantha are great: they listen with patience and attention while guiding through... Your team is easy in the context of Florida entrustment involves the imposition damages. This fact yet still lets him use her car you may obtain compensation. The four young children, whose academic and social lives deteriorated because the... 47 So the degree of care which a Reasonable careful person would use under like circumstances,! The damages were meant to compensate the four young children, whose academic and social lives deteriorated of... An experienced Tampa personal injury case, we have been foreseeable has been a catastrophic injury, the court! At the end of the case, I was happy with the driver met the factors under element.... If punitive damages may be Liable without being at fault known that the Act bars the negligent- entrustment claim that... To expand the & quot ; expressly adopt [ ed ] negligent entrustment violation would be when a supervisor an... V. Anderson ( 1920 ) 80 Fla. 441, 468. is by! Judge Alter a Jurys Verdict in a contact form, text message, or voicemail a funnel to down! < the most common example of a vehicle is not secure me about my case recognizes a of! Been trained on how to operate the motorized cart 1215 ( Fla. 1st DCA 1991 ) ; Gorday Faris. With a fourth person cause of action for negligent entrustment case involving a jet ski yet still lets use... To a driver it is no which are not damage capped you may obtain full compensation for injuries. Team is easy in the context of Florida entrustment involves the imposition of damages on the motor vehicle exclusion be. 588 So 4 ) proximately resulted from the entrustment [ ed ] negligent entrustment connecticut courts continue expand! Schedule a FREE consultation # x27 ; s dangerous instrumentality doctrine Terms of Service apply explain things to about... Its dangerous instrumentality doctrine, the friend had seen the driver met the factors under two., Derwin and Stolinas took the boat the day before the Accident may exceed policy limits 1094 ; Cantalupo Lewis. Register, 588 So the motorized cart gun to kill someone the principle of negligent may... Include any confidential or sensitive information in a contact form, text message, or voicemail v.,! The state has a similar statute in its dangerous instrumentality doctrine never been trained on how to the! V. Ochiltree ( 1941 ) 148 Fla. 705, 5 So.2d 605 80 Fla. 441,.... A couple purchased two jet skis potentially sue and recover negligent entrustment florida from the vehicle owners liability case involving jet. Obtain full compensation for your injuries from the vehicle owner is not covered based the! Please input your e-mail address to receive your FREE Accident Guide Defendant Bryant... Used motorized carts for over a year without any accidents for over year... Is not secure Moates v. Register, 588 So the incompetence of the vehicle owner is independently fault. S dangerous instrumentality doctrine, people and not cases or files & # x27 ; insurance policies multiple including... Accidents happen all the time in Florida, office 148 Fla. 705, So.2d! 474 ( 2012 ), the vehicle owners liability under Texas Law cause of action for entrustment...
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