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Budget Rent-a-Car System, Inc. v. Chappell

407 F.3d 166 (2005)

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Budget Rent-a-Car System, Inc. v. Chappell

United States Court of Appeals for the Third Circuit

407 F.3d 166 (2005)

Facts

Joseph Powell (defendant) was a Michigan resident, and his girlfriend, Nicole Chappell (defendant) was a New York resident. Powell rented a car from Budget-Rent-a-Car System, Inc. (Budget) (plaintiff) in Michigan, drove the car to New York to stay with Chappell, and then set out to drive back to Michigan with Chappell as his passenger. While driving through Pennsylvania, Powell fell asleep at the wheel, and the car flipped over. Powell did not suffer substantial injuries, but Chappell was permanently paralyzed. Chappell returned to New York and received medical treatment and care from medical providers in New York with the aid of a New York welfare program. Budget initiated an action against Powell and Chappell in Pennsylvania district court, seeking a declaratory judgment regarding which state’s substantive law governed Budget’s vicarious liability as the owner of the vehicle. Budget argued for Michigan law, which capped vicarious liability at $20,000, while Chappell argued for New York law, which provided unlimited vicarious liability. The district court granted summary judgment for Budget based on applying Pennsylvania law, which disallowed vicarious liability. The matter was appealed.

Rule of Law

Issue

Holding and Reasoning (Ambro, J.)

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