I often receive questions regarding the “rules” which apply to accidents involving rental vehicles, loaner vehicles, leased vehicles, demos, spot-delivered vehicles, etc. I thought I’d take some time to update some of my seminar materials and provide an update. The following is a portion of my updated materials. (I will provide more “specialized” rules in subsequent posts to this blog. You can receive future blog posts automatically via e-mail by subscribing to the blog).
In many states, the owner of a motor vehicle is required to insure the vehicle under a liability policy which, in addition to insuring the owner, extends “omnibus” protection to a permissive user of the vehicle. “Omnibus protection is the extension of liability coverage to a permissive user of a motor vehicle owned and insured in the name of another.” Agency Rent-A-Car, Inc. v. American Family Mut. Auto. Ins. Co., 519 N.W.2d 483, 485, n.2 (Minn. Ct. App. 1994). In the majority of jurisdictions, the omnibus coverage afforded to permissive users under the owner’s policy is deemed primary vis a vis the coverage available to the permissive user under his/her personal auto policy. This “priority” result is often mandated by operation of the policies “other insurance” clauses or by application of common law “closeness to the risk” tests developed by the courts or by statute. In some such jurisdictions, the limits of liability available to the permissive user under the owner’s omnibus coverage must be co-extensive with the limits available to the named insured. See, e.g., Smith v. National Indem. Co., 205 N.W.2d 365 (Wis. 1973) (car rental coverage contract which limited liability coverage for renters to less than coverage for rental agency was held invalid); Hardware Mut. Ins. Co. v. General Accident Fire & Life Ins. Co., 188 S.E.2d 218, 221 (Va. 1972) (court held that statute’s remedial intent prohibited split-limit provisions). In other words, if the owner’s policy affords $100,000 liability limits to the owner, the policy must also extend $100,000 of omnibus coverage to permissive users.
By contrast, the Minnesota No-Fault Act (enacted in 1975), has never contained a statute requiring the policy issued to the owner extend omnibus coverage to a permissive user of the vehicle. See, Minn. Stat. §65B.49, subd. 3(2). Prior to the adoption of the No-Fault Act, Minnesota law mandated omnibus liability coverage. Minnesota Statute § 170.40, subd. 2(2) (1971) provided that the owner’s policy must “insure the person named therein and any other person, as insured, using any such motor vehicle or motor vehicles with the express or implied permission of such named insured, against loss from liability imposed by law for damages arising out of the ownership, maintenance or use of such motor vehicle or motor vehicles.” Minn. Stat. § 170.40, subd. 2(2) (1971) (emphasis added). This statute imposed an omnibus coverage requirement on the owner’s insurer; however, it did not survive passage of the No-Fault Act.
In Leegard v. Universal Underwriters Ins. Co., 255 N.W.2d 819 (Minn. 1977), the Minnesota Supreme Court stated, in dictum, that an owner’s policy is only required to protect those “insureds” identified in Minn. Stat. §65B.43, subd. 5 (i.e., the named insured and resident relatives), which was not broad enough to encompass permissive users. Consequently, there is nothing in the No-Fault Act which specifically mandates that an owner’s policy extend omnibus coverage.
Despite the absence of any omnibus coverage requirement in the No-Fault Act, the Minnesota Department of Commerce and Minnesota courts have always assumed that this obligation exists. Historically, the Minnesota Department of Commerce has refused to approve for filing any personal auto policy that does not extend omnibus coverage to permissive drivers. In addition, in the early 1990’s, the Minnesota Department of Commerce held that rental contract provisions which purported to shift all insuring obligations to permissive users were invalid, suggesting that omnibus coverage is required. The presence of an “implied” omnibus coverage requirement gained further traction in McClain v. Begley, 465 N.W.2d 680, 682 (Minn. 1991). In that case, the self-insured rental car company attempted, through its rental car contracts, to shift all financial responsibility to its renters. The rental car contract in McClain required renters to assume full responsibility to the public and hold harmless and indemnify the rental car company from all liability. In an administrative proceeding, the Minnesota Department of Commerce found the rental car contact void and unenforceable under the No-Fault Act. On appeal to the Minnesota Supreme Court, the rental car company did not contest the Department of Commerce’s ruling that the rental contract was void. Rather, it only argued that it could only be required to extend minimum limits of omnibus coverage to the renter (i.e., $30,000 per person/$60,000 per accident) despite having filed a self-insured certificate with the Minnesota Department of Commerce identifying a self-insured retention (SIR) of $500,000. The Supreme Court, observed that “[s]elf insurance is the functional equivalent of a commercial insurance policy,” and went on to estop the rental car company from denying coverage in any amount less than the SIR. In other words, the self-insured rental car company was required to extend $500,000 of omnibus liability coverage to the renter. In a concurring opinion, which was considerably more thoughtful than the majority analysis, Justice Simonett concluded that a self-insured entity should be treated “as if it had purchased a policy of auto liability insurance for each of its vehicles with itself as the named insured. Such a policy, if purchased, would contain an omnibus clause extending coverage to permissive drivers as additional unnamed insureds.” Id. at 684. Justice Simonett noted that a vehicle owner could limit the amount of coverage available to permissive users by contract, but in this case, the rental car contract was void. Justice Simonett, thus, concluded that there was no contractual provision which served to limit the omnibus coverage and, consequently, the renter was entitled to receive the full $500,000 SIR.
Thus, the Minnesota Supreme Court’s decision in McClain superseded prior decisions that the presumptive amount of a self insurer’s omnibus liability insurance, absent any evidence of limits, was the statutory no-fault minimum. See, e.g. Anderson v. Northwest Bell Tel. Co., 443 N.W.2d 546, 549 (Minn. Ct. App.1989).
The leading case and most-often cited rental car case in Minnesota is Agency Rent-A-Car, Inc. v. American Family Mut. Auto. Ins. Co., 519 N.W.2d 483 (Minn. Ct. App. 1994), a case the author handled for Agency-Rent-A-Car. In Agency Rent-A-Car, the rental car company (Agency) had a self-insured retention (SIR) of $500,000 and a $5 million excess policy. The rental car contract provided that Agency would afford minimum limits ($30,000 per person/$60,000 per accident) of liability protection to its renters. At the time of the accident, Gruett (the renter) was insured with American Family under a personal auto policy affording $50,000 limits. Gruett caused an accident and the other driver sustained $87,000 in damages. American Family argued that Agency was obligated to extend its entire $500,000 SIR to Gruett on a primary basis, such that American Family’s policy would not come into play – the damages, as noted, were only $87,000. Agency argued that neither the No-Fault Act nor public policy required an owner of a vehicle, such as a rental car company, to afford liability protection to renters which is co-extensive with the level of protection the owner selected for itself. Agency acknowledged that it was obligated to pay $30,000 of omnibus coverage on behalf of the customer pursuant to the rental car contract, but contended that American Family was obligated to pay the next $50,000 of damages and Agency was then liable for the remaining $7,000 based on its vicarious liability under Minn. Stat. § 170.54. (Agency contended that it was legally entitled to indemnification for this $7,000 from Gruett, but agreed to waive the claim.
The trial court agreed with Agency on all grounds and the Minnesota Court of Appeals affirmed. The Court of Appeals noted that Agency was vicariously liable under Minn. Stat. § 170.54 (now § 169.09, subd. 5a) because it owned the rental vehicle that caused the accident and it had given the renter, the alleged tortfeasor, permission to drive it. However, the dispositive issue was not whether Agency and Gruett were jointly liable for the plaintiff’s damages of $87,000 (they were by operation of Minn. Stat. § 170.54), but rather whether and to what extent Agency or American Family, or both, were obligated to pay that liability. The Minnesota Court of Appeals agreed with Agency that it was obligated to pay the first $30,000 of damages, American Family was liable for the next $50,000 and Agency was responsible for the $7,000 balance (subject to its right of indemnification against the customer). The Court of Appeals noted:
[T]he dispositive determination in this case is [whether] the limit of [Agency’s] . . . omnibus coverage per person was $50,000 and not $500,000. * * * [American Family] argues that the liability limits a self-insurer reports to the Commissioner in the form of its self-insured retention must necessarily be coextensive with its omnibus liability limits per person per accident. * * * We agree with [Agency] that even if its insurance obligation was primary over that of [American Family], it successfully contracted to limit that primary insurance to $30,000, the statutory minimum. * * * Here, [Agency] executed a valid contract outlining the amount of omnibus liability coverage that it made available to lessees. * * * Courts in other states differ on whether a vehicle owner may carry one level of liability insurance for itself and a different level of omnibus coverage for permissive users. * * * Minnesota has no omnibus insurance statute. Courts in other states lacking such legislation have held that coverage for the named insured need not be coextensive with omnibus coverage. * * * We conclude that subject to the statutory minimum amount, an automobile rental company may limit its omnibus liability coverage to less than its own personal liability coverage, and it may do so in the rental contract. * * * We conclude that respondent has not unlawfully circumvented its duties as a self-insured no-fault reparation obligor. * * * And limited coverage does not defeat the purpose of the Act, as long as there are no uncompensated victims.
The Agency Rent-A-Car case was thus the first Minnesota case to specifically hold that the limits of liability available to a permissive user under the owner’s omnibus coverage need not be co-extensive with the limits available to the named insured. The insurer of the vehicle owner can limit the omnibus coverage it provides to permissive users to the statutory minimum limits while affording greater limits to the named insured owner. The McClain case, which was distinguished in Agency Rent-A-Car, stands for the narrow proposition that in the absence of any agreement or other evidence to the contrary, and where the only evidence of insurance protection for accident victims is found in the self-insured obligor’s representations to the Commissioner in its application for self-insurance, then those representations shall constitute the limit of the obligor’s liability coverage to the accident victims. (The case also recognized that the insurer of the vehicle would have a right of indemnification against the permissive user if the damages exceeded the omnibus coverage afforded to the permissive user under the owner’s policy).
In 1994, a week or so before the Court of Appeals issued its decision in Agency Rent-A-Car, the Minnesota legislature enacted a priority statute for automobile liability coverage (referred to as “residual liability coverage” in the No-Fault Act). Minnesota Statute § 65B.49, subd. 3(3)(d) provides in part that “a residual liability insurance policy shall be excess of a nonowned vehicle policy whether the nonowned vehicle is borrowed or rented, or used for business or pleasure.” The statute is not a model of clarity. According to the Minnesota Department of Commerce and Minnesota courts, the statute is to be interpreted from the standpoint of the permissive user. When viewed from this perspective, the statute requires the insurer of the vehicle owner (the insurer of the “nonowned vehicle”) to afford primary liability coverage to the permissive user vis a vis the coverage afforded to the permissive user under his/her personal auto policy. This priority statute essentially codified the order of payment which resulted under common law. Prior to enactment of Minn.Stat. § 65B.49, subd. 3(3)(d) in 1994, priority was determined by a “closest to the risk” analysis. See, e.g., Interstate Fire & Cas. Co. v.. Auto-Owners Ins. Co., 433 N.W.2d 82, 86 (Minn.1988); State Farm Mutual Auto. Insurance Co. v. Budget Rent-A-Car, Inc., 359 N.W.2d 673 (Minn. Ct. App. 1984).
Following enactment of § 65B.49, subd. 3(3)(d), Minnesota courts held that contractual provisions which attempted to shift the obligation to afford primary liability coverage from the insurer of the vehicle owner to the permissive driver’s insurer were void and unenforceable. See, e.g., Hertz Corp. v. State Farm Mut. Ins. Co., 573 N.W.2d 686, 689 (Minn. 1998) (rental contract which obligated renter to assume all liability if renter had personal auto policy was void under No-Fault Act); Mutual Service Cas. Ins. Co. v. West Bend Mut. Ins. Co., 599 N.W.2d 585 (Minn. Ct. App. 1999) (holding that garage liability policy defining an “insured” to exclude a customer who had personal auto coverage contravened the No-Fault Act). According to the Minnesota Court of Appeals, the Hertz and Mutual Service decisions, “on the basis of Minn. Stat. § 65B.49, subd. 3(3)(d), found an attempt to provide liability coverage only to permissive drivers who did not have liability coverage arising from his or her own automobile policy violated the policy of the No-Fault Act.” State Farm Mut. Ins. Co. v. Universal Underwriters Co., 625 N.W.2d 160 (Minn. Ct. App. 2001), rev. denied (Minn. June 21, 2001). The contractual provisions at issue were held void and unenforceable because the vehicle owner was “thrusting upon the renter its responsibility to provide liability coverage.” Id. (The Hertz and Mutual Service decisions are debatable. As noted by the Minnesota Court of Appeals in two other cases, “limited coverage does not defeat the purpose of the Act, so long as there are no uncompensated victims.” Agency Rent-A-Car, Inc. v. American Family Mutual Insurance Co., 519 N.W.2d 483 (Minn. Ct. App. 1994). See also American Family Mut. Ins. Co. v. Universal Underwriters Ins. Co., 438 N.W.2d 701 (Minn. Ct. App. 1989). In neither Hertz nor Mutual Service would the injured party have been affected had the contract provisions at issue been upheld. The insurance would have simply been shifted between the insurers. Minnesota Supreme Court Justice Alan Page correctly analyzed the issue in his dissenting opinion in Hertz, but the same is beyond the scope of this post).
There are three important principles for garage insurers, rental car companies and personal auto insurers to keep two things in mind when addressing claims. First, it is important to recognize that the priority statute, § 65B.49, subd. 3(3)(d), has no effect on the Agency Rent-a-Car decision and its authorization for “split-limits” policies. The priority statute only requires (subject to the exceptions identified below) that the first layer of coverage – the omnibus coverage available under the owner’s policy, come first. The priority statute does not mandate the limits of that omnibus coverage or require that those limits be co-extensive with the limits available to the named insured vehicle owner. In State Farm Mut. Ins. Co. v. Universal Underwriters Co., 625 N.W.2d 160 (Minn. Ct. App. 2001), a customer of an automobile dealership insured by Universal caused an accident while operating a loaner vehicle. The driver of the other vehicle was injured in the accident. The Universal garage liability policy afforded $500,000 in liability limits for the named insured dealership and its employees, but contained a split-limit, step down provision limiting liability coverage for customers (omnibus insureds) to the “limit needed to comply with the minimum limits provision law in the jurisdiction where the occurrence took place.” Id. at 162. Universal, represented by the author, acknowledged that it was required to afford the first $30,000 of liability coverage (the minimum limits required by Minnesota law) on behalf of the permissive user/customer, after which State Farm (which insured the customer under a personal auto policy) would apply. Finally, Universal contended that if the injured plaintiff still had uncompensated damages, the coverage Universal afforded to the dealership would be available for the balance of the injuries. State Farm, on the other hand, argued that Minn. Stat. § 65B.49, subd. 3(3)(d) prohibited an insurer from contractually providing different liability limits for a permissive driver and motor vehicle owner. State Farm contended that Universal was obligated to extend its full $500,000 liability limits as omnibus coverage to the renter.
The district court did not err in concluding that the policy clearly limits coverage for permissive drivers to the statutory minimum and that the higher limit continues to apply to the owner’s vicarious liability for such use. * * * This court has previously held that a self-insured owner of a motor vehicle may contractually limit liability coverage for a permissive user to the statutory minimum, while providing a higher coverage limit for the owner. See Agency Rent-A-Car, Inc. v. American Family Mut. Auto. Ins. Co., 519 N.W.2d 483, 487 (Minn. Ct. App. 1994). The decision in Agency involved a self-insured car-rental agency and the contractual limitation was contained in the rental agreement, but the analysis is not limited to self-insureds. * * * We noted in Agency that Minnesota does not have an “omnibus statute” requiring coverage of the named insured to be coextensive with coverage of any other person using the insured’s vehicle . . . Nothing in Minn. Stat. § 65B.49, subd. 3(3)(d) shows a clear intent by the legislature to restrict an insurer’s right to freely contract for different liability limits for permissive drivers and owners so long as the minimum statutory coverage is provided. * * * The remedial purpose of the Minnesota No-Fault Act is not impacted by allowing split limits. We find Agency controlling. Minn. Stat. § 65B.49, subd. 3(3)(d) does not void the split-limit coverages provided in Universal’s policy.
Thus, although a vehicle owner’s insurer is required to afford primary coverage by operation of the automobile liability priority statute, Minn. Stat. § 65B.49, subd. 3(3)(d), Minnesota insurers (and self-insureds) can, consistent with Agency Rent-A-Car, Inc. v. American Family Mut. Auto. Ins. Co., 519 N.W.2d 483 (Minn. Ct. App. 1994) and State Farm Mut. Ins. Co. v. Universal Underwriters Co., 625 N.W.2d 160 (Minn. Ct. App. 2001), rev. denied (Minn. June 21, 2001), contractually limit the omnibus coverage afforded to permissive drivers to the statutory minimum, while providing a higher coverage limit for the named insured vehicle owner. “[A] policy, if purchased, would contain an omnibus clause extending coverage to permissive drivers as additional unnamed insureds.” Hertz Corp. v. State Farm Mut. Ins. Co., 573 N.W.2d 686, 689 (Minn. 1998) (quoting McClain v. Begley, 465 N.W.2d 680, 684 (Minn. 1991) (J. Simonett, concurring). Although Minnesota has no omnibus statute, the omnibus coverage afforded under the owner’s policy is required to afford coverage to the permissive driver, at least up to the omnibus coverage limit identified in the policy (or rental car contract). Several other states have likewise found that split limits do not violate public policy. See, e.g., Bowers v. Estate of Feathers, 448 Pa.Super. 263, 671 A.2d 695, 700 (1995) (listing states which upheld split-limit provisions); Lehman Eastern Auto Rentals, Inc. v. Brooks, 370 So.2d 14, 16 (Fla.Dist.Ct.App.1979); Universal Underwriters Ins. Co. v. Hill, 24 Kan.App.2d 943, 955 P.2d 1333, 1339 (1998); Windsor Ins. Co. v. Lucas, 24 S.W.3d 151, 154-55 (Mo.Ct.App.2000); Yosemite Ins. Co. v. State Farm Mut. Auto. Ins., 98 Nev. 460, 653 P.2d 149, 150 (1982).
Second, it is important to bear in mind that the automobile liability priority statute, Minn. Stat. § 65B.49, subd. 3(3)(d),only sets forth the “general” priority rule. The statute is subject to the exception contained in Minn. Stat. § 65B.49, subd. 5a. See, Minn. Stat. § 65B.49, subd. 3(3)(d) (“[e]xcept as provided in subdivision 5a, a residual liability insurance policy shall be excess of a nonowned vehicle policy . . .”).
In 2000, Minn. Stat. § 65B.49, subd. 5a (j) was enacted and provided as follows:
The plan of reparation security covering the owner of a rented motor vehicle is excess of any residual liability coverage insuring an operator of a rented motor vehicle if the vehicle is loaned as a replacement for a vehicle being service or repaired, regardless of whether a fee is charged for use of the vehicle, provided that the vehicle so loaned is owned by the service or repair business.
In 2007, § 65B.49, subd. 5a(j) was amended to provide:
The plan of reparation security covering the owner of a rented motor vehicle is excess of any residual liability coverage insuring an operator of a rented motor vehicle.
A vehicle is considered “rented” for purposes of the “rented motor vehicle” priority statute “(1) if the rate for the use of the vehicle is determined on a monthly, weekly, or daily basis; or (2) during the time that a vehicle is loaned as a replacement for a vehicle being serviced or repaired regardless of whether the customer is charged a fee for the use of the vehicle.” Minn. Stat. § 65B.49, subd. 5a(b). “A vehicle is not rented if the rate for the vehicle’s use is determined on a period longer than one month or if the term of the rental agreement is longer than one month or the rental agreement has a purchase or buyout option or otherwise functions as a substitute for purchase of the vehicle.” Id.
There have been no reported appellate cases construing the “rented motor vehicle” priority statute, Minn. Stat. § 65B.49, subd. 5a(j). Presumably, under the “rented motor vehicle” priority statute, the personal auto policy insuring the operator of the “rented” vehicle is required to afford primary liability coverage up to its stated limits of liability. (This insuring obligation is reinforced by Minn. Stat. § 65B.49, subd. 5a(a), which requires that every plan of reparation security wherever issued insuring a natural person as a named insured . . . extend the plan’s basic economic loss benefits, residual liability insurance, and uninsured and underinsured motorist coverages to the operation or use of the rented motor vehicle.” Id. (emphasis supplied)). If uncompensated damages remain, the policy (or self-insurance) insuring the vehicle would then be required to extend at least $30,000 per person/$60,000 of liability coverage, the minimum limits required by Minnesota law, just like the owner of any motor vehicle. To the extent uncompensated damages remain and the vehicle owner is vicariously liable (see my prior blog posts addressing the impact of the Graves Amendment which abolishes vicarious liability for rental car owners and the No-Fault Act’s statutory cap on vicarious liability for rental car owners), the policy (or self-insurance) insuring the vehicle owner would pay the balance of the damages the owner is legally obligated to pay, up to its liability limits.
In my view, the case of Johnson v. Americar Rental Sys., 613 N.W.2d 773, 776 (Minn. Ct. App. 2000), review denied (Minn. Sept. 26, 2000), involving an accident that occurred several years prior to the passage of the federal Graves Amendment in 2005 and the amendment to Minn. Stat. § 65B.49, subd. 5a(j) in 2007, was incorrectly decided. In that case, Americar owned a rental car that was involved in a one car accident. Johnson, a passenger, was injured. At the time of the accident, Americar was insured by National Casualty. As was the case in Agency Rent-A-Car, the National Casualty policy afforded split-limits: $1,000,000 limits for Americar, the vehicle owner, and $30,000 per person/$60,000 per accident for permissive drivers. Johnson’s husband, the driver of the rented vehicle, was insured by American Family with limits of $100,000 per person. The parties stipulated that Johnson’s husband was responsible for causing the accident and that Johnson’s damages totaled $225,000. The parties also agreed that National Casualty was responsible for the first $30,000 of stipulated damages and that American Family was responsible for the next $100,000 of damages, a total of $130,000. The dispute centered on the remaining $95,000 of damages. The trial court held that Americar was vicariously liable for the final $95,000 of damages and, thus, its insurer was obligated to pay the balance. Thus, under the trial court’s ruling, Johnson would have been fully compensated. However, the Minnesota Court of Appeals reversed. The Court of Appeals determined that Americar’s maximum vicarious liability obligation was $105,000 (based on application of the vicarious liability cap statute, Minn. Stat. § 65B.49, subd. 5a(i)(2)) and Americar was entitled to deduct National Casualty’s initial payment of $30,000 against Americar’s vicarious liability. Thus, instead of Americar/National Casualty paying an additional $95,000 to Johnson, only $75,000 was paid to Johnson. As a result, Johnson received $205,000 in liability compensation, $20,000 less than her total damages. The problem with the holding in Johnson is that the Court of Appeals viewed the initial $30,000 payment as payment for Americar’s vicarious liability when, in fact, it was paid because National Casualty was required by statute and case law to afford $30,000 of omnibus liability protection to the permissive driver/renter. See, Agency Rent-A-Car, Inc. v. American Family Mut. Auto. Ins. Co., 519 N.W.2d 483, 488 (Minn. Ct. App. 1994) (“[w]e conclude that subject to the statutory minimum amount, an automobile rental company may limit its omnibus liability coverage to less than its own personal liability coverage, and it may do so in the rental contract”). While an insurer’s satisfaction of an omnibus coverage obligation always serves to indirectly benefit the vicariously liable vehicle owner (by serving to satisfy a portion of the injured party’s damages), the payment is made to satisfy the financial responsibility or compulsory insurance requirements of the law, not the vehicle owner’s vicarious liability. National Casualty should have paid a total of $125,000 — $30,000 omnibus coverage limits on behalf of the renter and $95,000 on behalf of Americar. The issue is, however, moot for cases involving “rental cars” by virtue of the Graves Amendment.
Third, I have addressed the federal Graves Amendment in prior posts. It is important to note that the Graves Amendment’s broad preemption of vicarious liability for rental-vehicle owners is subject to a “savings clause” which preserves two types of state laws: (1) laws that impose financial responsibility or insurance standards on the owner for the privilege of operating a motor vehicle, and (2) laws that impose liability on businesses that rent or lease vehicles for their failure to meet the financial responsibility or liability insurance requirements. 49 U.S.C. § 30106(b). Thus, certain financial responsibility laws in Minnesota are preserved and not subject to the Graves Amendment. For example, Minn.Stat. § 65B.48, subd. 1, which requires the owner of a motor vehicle to maintain a “plan of reparation security [providing] for . . . residual liability coverage in amounts not less than those specified in section 65B.49, subdivision 3, clauses (1) and (2)” is not affected by the Graves Amendment. The minimum limit for liability insurance in Minnesota is $30,000 per person and $60,000 per accident. Minn. Stat. § 65B.49, subd. 3(1). The $30,000/$60,000 liability limit is obviously not affected by the Graves Amendment. Thus, even if the rented vehicle owner has no vicarious liability, the vehicle owner, and its liability insurer, must still maintain and extend at least minimum limits coverage.
This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney licensed in your jurisdiction. © All rights reserved. 2010.