Rig Masters, Inc. v. Katie Colenberg, Individually and on Behalf of the Heirs and Wrongful-Death Beneficiaries of Isaac Pearl Colenberg (Deceased) and Thomas A. Sturdivant

Summary

The Mississippi Supreme Court reviewed an interlocutory appeal from the denial of summary judgment on a negligent-entrustment claim arising from a fatal automobile accident. The Court held that the plaintiff failed to present sufficient evidence that Rig Masters knew or should have known of the driver's alleged substance-abuse problem, retained control of the truck, or that the alleged substance abuse directly correlated with the accident, and therefore reversed and remanded.

Holdings

1. A prima facie negligent-entrustment claim requires proof that the defendant supplied a chattel to a third party; knew or should have known that the third party would use it in a manner involving an unreasonable risk of harm; harm resulted from the use; the chattel was under the supplier's control; and the supplier's known or knowable dangerous conduct had a direct correlation to the harm.
2. The evidence was insufficient to show that Rig Masters knew or should have known, when it sold the truck, that Sturdivant had a substance-abuse problem making him an unreasonable hazard to other drivers.
3. Rig Masters did not retain the control required for negligent-entrustment liability merely because title and insurance remained in its name.
4. The negligent-entrustment claim failed because no evidence showed that Sturdivant was under the influence of drugs or alcohol at the time of the accident or that alleged substance abuse contributed to the collision.

Questions Presented

1. Whether the circuit court erred by denying Rig Masters summary judgment on the negligent-entrustment claim.
2. Whether the evidence established genuine issues of material fact concerning Rig Masters' knowledge of Sturdivant's alleged substance-abuse problem, control of the truck, and a direct correlation between the alleged substance abuse and the accident.
3. Whether Rig Masters could be liable for negligent entrustment merely because title and insurance remained in its name after Sturdivant purchased the truck.

Disposition

reversed_and_remanded