Client Advisory

The Connecticut Appellate Court handed a win to rental companies facing negligent entrustment claims in Connecticut, refusing to impose upon them a duty to inspect their customers’ driver’s licenses.

In Stanford v. Nogiec, 233 Conn. App. 862 (2025), defendant Nogiec rented a vehicle from Enterprise. Before renting the vehicle to Nogiec, an Enterprise employee confirmed that Nogiec’s license was facially valid, contained no restrictions on its face, and had not expired. He also observed that Nogiec did not demonstrate any signs of impairment or other signs of unfitness to operate a vehicle. However, Nogiec, unbeknownst to Enterprise, was restricted from operating a vehicle without an Interlock device, which would prevent him from driving unless he was sober. Later that day, Nogiec struck Stanford, a pedestrian, while under the influence.

Plaintiffs asserted a negligent entrustment claim premised on Enterprise’s duty to inspect Nogiec’s license. Plaintiffs claimed that Enterprise was required investigate whether Nogiec’s license was suspended or restricted him from driving without the use of an Interlock device, a significant extension beyond the requirements outlined in Conn. Gen. Stat. § 14-153, which requires only that rental companies inspect the license and compare its signature to the signature on the contract.

Enterprise filed for summary judgment, arguing that it did not have a duty to investigate Nogiec’s driver’s license status, motor vehicle history, or criminal history. The trial court granted summary judgment, agreeing that Enterprise had no duty to do anything more than Conn. Gen. Stat. § 14-153 required.

The Appellate Court affirmed the trial court’s view that inspecting a license under the statute requires only that rental car companies confirm the license’s facial validity, explicitly rejecting the plaintiffs’ claim that the statute requires rental car companies to use an online database to investigate the status of a facially valid license. The Appellate Court also rejected the plaintiffs’ attempt to create a common-law duty that would require rental car companies to investigate the status of a facially valid license. Ultimately, the Court determined that Enterprise satisfied its duty when the employee who rented the vehicle to Nogiec confirmed he did not demonstrate any signs of impairment or unfitness. Therefore, Enterprise was entitled to summary judgment.

Key Takeaway: A rental car company’s duty under a negligent entrustment theory depends on whether readily apparent facts give the company a reason to suspect that the driver is incompetent to drive.