Enterprise Rent-A-Car of L.A. v. Super. Ct.

INTRODUCTION

Vehicle Code1 section 14608 provides, in relevant part: “(a) A person shall not rent a motor vehicle to another person unless both of the following requirements have been met: [¶] (1) The person to whom the vehicle is rented is licensed under this code or is a nonresident who is licensed under the law of the state or country of his or her residence. [¶] (2) The person renting to another person has inspected the driver’s license of the person to whom the vehicle is to be rented and compared either the signature thereon with that of the person to whom the vehicle is to be rented or the photograph thereon with the person to whom the vehicle is to be rented.” In this case of first impression, we consider whether section 14608 imposes a duty on a rental car agency to investigate a prospective renter’s residence status when he or she, at the time of rental, provides the agency with: (1) a facially valid foreign driver’s license; and (2) a local California address on the rental paperwork. We decide it does not. As discussed further below, requiring a rental car agency to investigate whether a prospective renter who presents a facially valid foreign driver’s license is still…