Guardianship of Garvin ex rel. Sullivan v. Tupelo Furniture Market, Inc.

Summary

The Mississippi Supreme Court reviewed an interlocutory appeal from summary judgment on claims of negligent entrustment and negligent training or instruction arising from a vehicle collision involving a minor driver. The court held that no genuine issue of material fact supported negligent-entrustment liability because the driver was not under the influence at the time of the accident and affirmed summary judgment. It also affirmed summary judgment on the negligent-training claim because no duty to instruct was established and there was no evidence of detrimental reliance.

Holdings

1. Summary judgment was proper because Miller's age, valid license, limited prior driving history, and prior alcohol or marijuana use did not create a genuine issue of material fact that Melanie negligently entrusted the vehicle to Miller when Miller was sober and unimpaired at the time of the accident.
2. Summary judgment was proper because no genuine issue of material fact existed as to negligent entrustment, making any dispute over whether V.M. Cleveland or TFM had the right to control the vehicle immaterial.
3. Summary judgment was proper because Mississippi law imposed no duty on V.M. Cleveland to teach Miller to drive, and, even assuming he voluntarily undertook such a duty, Garvin presented no evidence that she detrimentally relied on the undertaking.

Questions Presented

1. Whether the trial court erred in granting summary judgment on Garvin's negligent-entrustment claims against Melanie Cleveland, V.M. Cleveland, and Tupelo Furniture Market, Inc.
2. Whether the trial court erred in granting summary judgment on Garvin's negligent-training or instruction claim against V.M. Cleveland.

Disposition

affirmed