Young v. Beck, 227 Ariz. 1

Summary

The Arizona Supreme Court considers whether the family purpose doctrine remains valid, whether Arizona statutes abrogated it, and whether it was properly applied to impose vicarious liability on the vehicle owners. The court holds that the Uniform Contribution Among Tortfeasors Act and Financial Responsibility Act did not abrogate the doctrine, declines to abolish it, and affirms summary judgment for Amy Young because the vehicle was furnished for family use and Jason used it with permission, despite violating specific restrictions.

Holdings

1. The 1987 amendments to Arizona's Uniform Contribution Among Tortfeasors Act did not abrogate the family purpose doctrine because the statute did not clearly and plainly manifest legislative intent to eliminate the doctrine, which is a form of vicarious liability.
2. Arizona's Financial Responsibility Act did not preempt, replace, limit, or abrogate the family purpose doctrine.
3. The court declined to abolish the family purpose doctrine.
4. The doctrine applies when a head of family furnishes or maintains a vehicle for the family's general use, pleasure, and convenience, and a family member uses it with the head's express or implied permission for a family purpose.

Questions Presented

1. Whether Arizona's family purpose doctrine was abrogated by the 1987 amendments to the Uniform Contribution Among Tortfeasors Act.
2. Whether Arizona's Financial Responsibility Act preempted, limited, or abrogated the family purpose doctrine.
3. Whether the Arizona Supreme Court should abolish the family purpose doctrine as a matter of common law.
4. Whether the family purpose doctrine applied as a matter of law when the minor family member used the vehicle for personal pleasure and convenience and violated parental restrictions on transporting friends.
5. Whether Young was entitled to partial summary judgment on the doctrine's applicability.

Disposition

affirmed