Moyer Car Rental, Inc. v. Halliburton Co.

1980 OK 59, 610 P.2d 232, 1980 Okla. LEXIS 239
CourtSupreme Court of Oklahoma
DecidedApril 15, 1980
Docket49658
StatusPublished
Cited by3 cases

This text of 1980 OK 59 (Moyer Car Rental, Inc. v. Halliburton Co.) is published on Counsel Stack Legal Research, covering Supreme Court of Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Moyer Car Rental, Inc. v. Halliburton Co., 1980 OK 59, 610 P.2d 232, 1980 Okla. LEXIS 239 (Okla. 1980).

Opinion

BARNES, Justice:

In July, 1974, a Mr. Edward Van Eeckh-out rented an automobile from Moyer Car Rental, Inc., an Oklahoma corporation. While operating that vehicle, Mr. Van Eeckhout was involved in a two-car collision in Osage County, Oklahoma. The other vehicle involved in the collision was owned by the Halliburton Company and driven by Mr. Terry Robert Lacy, an employee and admitted agent of the Halliburton Company, a foreign corporation.

In April 1975, a suit was initiated by Moyer Car Rental, Inc., against the Halliburton Company, in which the rental car company sought to be compensated for damage to its rental automobile, allegedly caused by the negligence of Halliburton’s agent, Mr. Lacy. As the suit progressed, Halliburton filed a cross-petition, seeking to be compensated for damage done to its automobile, allegedly caused by the negligence of Mr. Van Eeckhout, the gentleman who rented the automobile from Moyer Car Rental. The cause was ultimately tried to a jury, and the jury determined that both Mr. Lacy and Mr. Van Eeckhout were 50% negligent. Thereafter, the trial court entered a judgment in which neither party recovered any damage, as each party had failed to prove that the other was more negligent than himself. Moyer Car Rental, Inc., appeals from that judgment, arguing that it was error for the trial court to impute the negligence of its lessee, Mr. Van Eeckhout, to it, and that if that negligence were not imputed to it, Moyer would have been 0% negligent and entitled to a judgment *234 against Halliburton. In support of this proposition, Moyer cites many cases in which this Court has held that the mere fact that an owner of a vehicle gives permission to a third party to operate the owner’s automobile is not, alone, sufficient grounds upon which to impute the negligence of the third party to the owner. Moyer also argues that 47 O.S.1971 § 8-102(c), does not operate to impute Mr. Van Eeckhout’s negligence to Moyer. Title 47 O.S.1971 § 8-102(c), upon which the trial court relied, provides:

“Any owner of a for-rent motor vehicle who has given proof of financial responsibility under this section or who in violation of this act has failed to give proof of financial responsibility shall be jointly and severally liable with any person operating such vehicle for any damages caused by the negligence of any person operating the vehicle by or with the permission of the owner, except that the foregoing provision shall not confer any right of action upon any passenger in any such rented vehicle as against the owner.” [Emphasis added]

Appellant Moyer argues that although the above quoted statute seems on its face to impute the negligence of a lessee of a for-rent vehicle to the owner of such a vehicle, an analysis of Chapter 8 of Title 47 in its entirety demonstrates that such liability is only to be imputed to the owner under the following circumstances: (1) when the owner of the vehicle has failed to give proof of financial responsibility in violation of Chapter 8 of Title 47, or (2) when the owner of a for-rent vehicle has chosen to give proof of financial responsibility under the provisions of 47 O.S., § 8-1202, rather than under the provisions of Section 8-101 of that Title. We agree with Appellant’s contention. Under the provisions of Chapter 8 of Title 47, the owner of a for-rent vehicle may give proof of financial responsibility either under the provisions of Section 8-101 1 of that chapter or under the provisions *235 of Section 8-102 2 of that Chapter.

Under the provisions of Section 8-101, the owner of a for-rent vehicle may give proof of financial responsibility in one of two ways, either of which involve the issuance of automobile liability insurance policies:

1. The owner may submit evidence that there has been issued to him by an insurance carrier authorized to do business in the State, a liability insurance policy or policies covering each for-rent vehicle owned, insuring every person operating such vehicle under a rental agreement or operating the vehicle with the express or implied permission of the owner against loss and liability imposed by law upon such person arising out of the operation of the vehicle. The owner must also show that such policies meet or exceed specific liability amounts required by that Section.
2. Alternatively, the owner of a for-rent vehicle may give proof of financial responsibility under the provisions of Section 8-101, by submitting evidence, satisfactory to the Commission, of a valid and binding lease contract between the owner and the lessee, wherein the lessee accepts the responsibility for loss from any liability imposed by law upon any person arising out of the operation of any vehicle *236 covered by such a lease agreement, together with satisfactory evidence of the issuance of a liability insurance policy to the lessee, which satisfies the statutory amounts, and other requirements.

When the owner of a for-rent vehicle gives proof of financial responsibility utilizing either of the above provided methods set forth in Section 8-101 of Title 47, any direct action against the owner should, pursuant to Section 8-101(e), be dismissed. That Section provides:

“When any suit or action is brought against the owner of a for-rent motor vehicle upon a liability under this act, it shall be the duty of the judge of the court before whom the case is pending to cause a preliminary hearing to be had in the absence of the jury for the purpose of determining whether the owner has obtained and there is in full force and effect a policy or policies of insurance covering the person operating the vehicle under a rental agreement in the limits above mentioned. When it appears that the owner has obtained such policy or policies and that the same are in full force and effect, the judge or magistrate before whom such action is pending shall dismiss the action as to the owner of the motor vehicle.” [Emphasis added]

Such, however, is not the case when financial responsibility is proven pursuant to the provisions of Section 8-102 of Title 47. Under the provisions of that Section, the owner of a for-rent vehicle may prove financial responsibility by demonstrating to the satisfaction of the Oklahoma Tax Commission that he or she has the financial ability to respond in damages, in accordance with set sums per vehicle and accident, set forth in that Section.

When the owner of a for-rent vehicle chooses to give proof of financial responsibility in this manner, prescribed by Section 8-102, that owner is deemed to be jointly and severally liable with any person operating such vehicle for any damages caused by the negligence of any person operating the vehicle by or with the permission of the owner.

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Cite This Page — Counsel Stack

Bluebook (online)
1980 OK 59, 610 P.2d 232, 1980 Okla. LEXIS 239, Counsel Stack Legal Research, https://law.counselstack.com/opinion/moyer-car-rental-inc-v-halliburton-co-okla-1980.