White V. Calkin Trial Brief

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Trial Brief The following is a trial brief prepared by Carmen Smith To: Carmen Smith From: Supervisory Attorney Date: February 16, 2014 Re: White v. Calkin, Civ 03-388 Jane White Plaintiff vs. Jeffery Calkin & Sage Rent-A-Car Defendants Brief in Support of Motion to Dismiss QUESTION PRESENTED Under the New Mexico Mandatory Financial Responsibility Act, (MFRA), NMSA 1978 Sections 66-5-201 to 66-5-239 and NMSA 1978 Section 66-5-205 (1998), can a lessor, who is self-insured by the superintendent of insurance, be held liable for damages caused by the negligent use of a vehicle by a lessee? STATEMENT OF THE CASE Our client, Sage Rent-A-Car Inc. leased a vehicle to Jeffery Calkin. Mr. Calkin collided with Jane White (the plaintiff) after failing to stop at a stop sign. Ms. White filed a negligence law suit against Mr. Calkin and our client, Sage Rent-A-Car siting a violation of the provisions under MFRA. Sage Rent-A-Car, Inc. filed a surety bond with the superintendent of insurance and is self-insured. ARGUMENT MS. WHITE’S ARGUMENT THAT SAGE RENT-A-CAR IS REQUIRED TO CARRY INSURANCE DOES NOT ESTABLISH THE DEFENDANT’S DUTY TO ASSUME RESPONSIBILITY FOR THE NEGLIGENCE OF MR. CALKIN AND THEREFORE FAILS TO STATE A CLAIM. This matter is before the court on Rule 1-012B(6) to file a motion to dismiss for failure to state a claim. In the case of Las Lumarias of the N.M. Council v. Isengard, 92 N.M. 297, 300-301 (Ct. App. 1978), the New Mexico Supreme Court established the standard for the granting of a Rule 1-012B(6) motion. The Court stated, “A motion to dismiss a complaint is properly granted only when it appears that the plaintiff cannot recover or be entitled to relief under any state of facts provable under the claim…” Under the provision of New Mexico Mandatory Financial Responsibility Act, (MFRA), NMSA 1978

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