In cases involving personal injuries caused by rented vehicles, vehicle rental or leasing companies have traditionally relied on the Graves Amendment (49 U.S.C. §30106) to shield themselves from vicarious liability for the actions of those driving their vehicles. Under the Graves Amendment, a vehicle owner may avoid liability if the vehicle is rented or leased, the owner engages in the business of renting vehicles, and the owner was not negligent or engaged in criminal wrongdoing. See Couchman v. Nunez, 180 A.D.3d 645(2020).

However, a recent decision in Caldeira v. EAN Holdings, LLC, 240 A.D.3d 654(N.Y. App. Div. 2d Dept’ 2025), makes clear that rental companies cannot rely solely on the Graves Amendment to dismiss claims when allegations of negligent maintenance exist.

In September 2019, the plaintiff was involved in a motor vehicle accident with a vehicle owned by EAN Holdings, LLC (“EAN”). Caldeira alleged that EAN had rented the vehicle to the defendant driver and further claimed that the collision was partially caused by EAN’s failure to properly maintain the vehicle, including providing insufficient or defective brakes.

EAN moved for summary judgment to dismiss the claims against it, arguing that the Graves Amendment protected it from liability. While the court found that EAN did demonstrate ownership of the vehicle and that it was engaged in the business of renting vehicles, it failed to show that there were no triable issues of fact regarding negligent maintenance. Specifically, EAN’s maintenance records did not prove that the brakes had been inspected or maintained prior to the accident.
The Supreme Court, Kings County, therefore denied EAN’s motion for summary judgment, and the appellate court affirmed. This decision highlights that vehicle rental companies must take reasonable steps to ensure their vehicles are safe and properly maintained; otherwise, claims of negligent maintenance may defeat Graves Amendment protections.

Giulia R. Marino, Esq.