Young v. Beck
Ariz. Supreme Court, April 5, 2011
Authored by the JSH Appellate Team
The Becks provided their seventeen-year-old son Jason with a vehicle to travel to and from school, church, and work. If he obtained permission, he could also use the vehicle for social and recreational purposes. After Jason got into an accident, his parents specifically instructed him not to “taxi” his friends or drive their girlfriends home. About a month later, Jason’s mother gave him permission to drive the vehicle to his friend’s house, spend the night there, and drive home the next day. She did not give him permission to use the vehicle for any other purpose. That night, Jason drove around with several friends as they threw eggs at houses and parked cars. On the way to drop off one of his friends, Jason’s vehicle collided with a vehicle driven by Young, who was seriously injured. Young sued the Becks under the family purpose doctrine. On cross-motions for partial summary judgment regarding the doctrine’s applicability, the superior court ruled in favor of Young. The court of appeals affirmed.
The Supreme Court also affirmed, rejecting the Becks’ arguments against the Family Purpose Doctrine. That doctrine states that the owner of an automobile is responsible for damages to anyone injured when the auto is driven by a member of the family, with or without the owner’s permission. The court first rejected the Becks’ argument that the Legislature abrogated the Family Purpose Doctrine when it abolished joint and several liability in most cases. The family purpose doctrine expressly rests on agency principles, and the Legislature carved out an agency exception to the abolishment of joint and several liability. Second, it rejected the argument that the Financial Responsibility Act (which requires vehicle owners to carry liability insurance and insurance policies to cover all permissive drivers), preempted the Family Purpose Doctrine. Requiring all Arizona vehicle owners to carry minimum limits of liability coverage is not inconsistent with imposing vicarious liability under the Family Purpose Doctrine. Furthermore, a law requiring minimum liability coverage of only $15,000 per person and $30,000 per occurrence does not guarantee that victims of serious accidents caused by young, inexperienced, and financially insecure drivers will be fully compensated. Finally, the policy goals underlying the Family Purpose Doctrine still exist today, and numerous states continue to follow the doctrine. Although policy arguments exist for and against the Doctrine, the court found no compelling reason to abolish it.