Salavarria v. National Car Rental System, Inc.

Louisiana residents Henry Salavarria and others (plaintiffs) were injured in Louisiana when Salavarria's car collided with a rental car owned by National Car Rental Systems (National) (defendant) and driven by Heather Trempe, who was not an authorized driver under the rental contract signed in Florida by Mitchell Brogdon. Salavarria sued National in Louisiana state court; National sought summary judgment based on a Louisiana law letting self-insured rental agencies contractually restrict vehicle use to authorized drivers, absolving them of liability for unauthorized drivers, but the trial court applied Florida law -- which imposed vicarious liability regardless of authorization -- and denied the motion, and National appealed.