In a unanimous decision, the Minnesota Supreme Court strictly enforced a federal regulatory scheme to preempt litigation that sought to impose personal injury liability upon rental-vehicle owners, here, Enterprise Rent-A-Car Co. Defendants may use this precedent in a variety of industries to illuminate the Court’s deference to federal regulation.
Meyer v. Nwokedi arose from a single-car accident in which two people were killed and two others were injured. The lawsuit named as defendants both the driver and owner of the rental car; the rental car company was sued on a theories of vicarious liability and negligent entrustment.
Despite finding federal preemption to be generally disfavored, the high court held the claims against the rental car company to be precluded by the Graves Amendment, 49 U.S.C. § 30106 (2006). The Court enforced the plain terms of the federal legislation (including exceptions) to hold that Congress prohibited the tort claims pressed by the plaintiffs.