Levy v. Daniels' U-Drive Auto Renting Co.
Connecticut Supreme Court
143 A. 163 (1928)
Sacks (defendant) rented a car in Connecticut from Daniels' U-Drive Auto Renting Company (defendant), then, while driving it in Massachusetts, stopped without adequate warning and, with a nonfunctioning taillight, was struck from behind by Maginn (defendant); Levy (plaintiff), a passenger in Sacks's car, was seriously injured. Levy sued all three in Connecticut court, basing his claim against U-Drive on a Connecticut statute imposing liability on anyone renting a car to a person whose operation of it causes injury during the rental period. The trial court sustained U-Drive's demurrer, reasoning that Massachusetts law, which imposed no such rental-based liability, governed instead of Connecticut's statute. Levy appealed.
Whether a liability statute that attaches upon the formation of a contractual relationship in one state applies when the conduct triggering liability occurs in another state.