LITTLES v. Avis Rent-A-Car System

Dissenting Opinion by

Mr. Justice Roberts:

When Alfred D. Kemp entered the Avis office to rent a. truck which was 24 feet long, eight feet wide and eleven feet high, the largest vehicle he had ever driven was a pick-up truck with considerably smaller dimensions. The only other evidence of his competence to handle this huge piece of machinery was his presentation of a valid Pennsylvania driver’s license. Since the rental agent was aware of this limited experience with over-sized vehicles, I think the provisions of section 390 of the Restatement of Torts definitely should have applied. The section states: “One who supplies directly or through a third person a chattel for the use of another whom the supplier knows or has reason to know to be likely because of his youth, inexperience or otherwise, to use it in a manner involving unreasonable risk of physical harm to himself and others whom the supplier should expect to share in or be endangered by its use, is subject to liability for physical harm resulting to them.”

Avis knew that Alfred Kemp was inexperienced in the driving of this size vehicle. He had never attempted to drive anything larger than a pick-up. Nor could the agents for Avis rely on the Pennsylvania driver’s license he carried as proof of his competence despite this lack of experience. It is common knowledge that licenses are issued to any individual who is capable of driving an automobile, although such person by reason of his or her size or lack of strength would never be able to handle a huge tractor with its sophisticated transmission and braking systems. See Piquet v. Wazelle, 288 Pa. 463, 465, 136 Atl. 787, 788 (1927) (li*77cense only prima facie evidence of fitness). I think that simply by showing that Kemp’s inexperience was known to Avis’ agents, plaintiff brought herself within the exact terms of section 390, contrary to the holding of the majority.*

However, this does not end the inquiry. This case should be remanded for resolution of two different issues. The first is exactly what Avis’ responsibility was once they realized their potential customer was unfamiliar with the operation of a twenty-four foot truck. It is a question for the jury what Avis in fact should have done to remove the taint of inexperience from the shoulders of Kemp. For example, a jury might determine that a simple warning about the major differences between this vehicle and the pick-up truck might have been sufficient. Perhaps Kemp should have been instructed about the differences in transmission, braking characteristics and size. Or it might be the judgment of the jury that the potential lessee should have been given a short demonstration drive to familiarize him with the operation of this ungainly vehicle. Whatever the jury’s finding, even if it were to determine, that a three hour or three day course was necessary to properly instruct Kemp, this clearly was an issue for its determination and should not have been taken away from the jury by the granting of the nonsuit.

*78The second issue is equally appropriate for the jury. Once the jury decides that Avis was negligent for.failing to rent either to an experienced individual or properly instruct one who was not, it still is tlieir responsibility as in any other negligence case to decide whether this act of negligence was the proximate cause of the accident. For example, in this case, the reason Kemp hit the railroad bridge may have been his inexperience in driving tall vehicles and the failure to warn him that this was one of the dangers inherent in driving an eleven foot high truck. But the jury also could find the reason to be that Kemp simply failed to pay attention to the road at the time of the accident. In the latter case, as in other tort cases, the finding of negligence would not result in a recovery since the negligent act would not be the proximate cause of the accident. It certainly seems beyond doubt that the appropriate action for the trial judge was to allow the jury also to decide this issue.

Since I- think the nonsuit was improperly granted I dissent from the majority opinion and would remand for a determination by the jury.

It is my view that section 390 requires, at a minimum, that lessor inquire as to the experience of the lessee in operating any unusual vehicle. Of course if the lessee lies and informs the rental agents that he has often driven a truck of this size, a plaintiff, would not be able to bring himself within section 390 unless there was some other reason why lessor should have known about lessee’s inexperience. For example, if lessee demonstrates a great deal of difficulty in starting the vehicle or maneuvering it out of lessor’s parking lot, lessor should not be allowed to rely on this misrepresentation. But if nothing suspicious occurs, lessor would be free of liability despite lessee’s lie.