Traffic Accident – Is a Trailer a “Vehicle” For Liability Purposes?
Lending equipment to a neighbor may seem harmless, but can it lead to a lawsuit? In this vicarious liability case, the issue was whether the owners of a trailer can be held vicariously liable under Iowa’s Owner Consent statute (Iowa Code §321.493). Ultimately, the courts agreed that the plaintiff’s claims should be dismissed against the trailer owners, because a trailer is not a motor vehicle in Iowa.
The facts of the case revealed that, in 2004, a farmer was operating his own tractor with an attached trailer (owned by a family member) on a state highway when he collided with a car. The driver of the car sustained serious injuries and his conservators filed a personal injury lawsuit on his behalf against the farmer and the owner of the trailer. At trial, the conservators alleged that the tractor and trailer were one unit or one motor vehicle, thus both the farmer and the family members were liable. But, the trial court found that the owner of the trailer was not liable for failing to maintain and equip the trailer in a safe manner, because the trailer owner was not the party operating the trailer. The Iowa Court of Appeals agreed.
On appeal the only issue before the Iowa Supreme Court was whether the trailer owners were vicariously liable for the farmer’s negligence. To resolve the issue, the court had to decide whether a trailer is a motor vehicle under Iowa law. The court stated that Iowa’s Owner Consent Statute states that when damage is done by any motor vehicle by reason of driver negligence, and driven by consent of the owner, the owner shall be liable. Thus, loaning a car to a driver who causes an accident can result in liability for the car’s owner. But, what about a separate item, such as a trailer, owned by someone else that is attached to the “vehicle”?
The Iowa Supreme Court determined that the Iowa legislature clearly did not intend a trailer when attached to a motor vehicle, in this case a tractor, to be classified as a motor vehicle. Under the Iowa Owner Consent Statute, this situation is merely a “combination of vehicles,” not one motor vehicle. Since the legislature did not clearly refer to a trailer as a motor vehicle when combined with another vehicle, it is clear that the legislature intended to exclude those portions of combination vehicles that are not also motor vehicles. The trailer, standing alone, qualifies as a vehicle, but when attached to a motor vehicle it does not qualify. Thus, the family member was not vicariously liable in this lawsuit. Zimmer v. Vander Waal, No. 08-0662, 2010 Iowa Sup. LEXIS 25 (Sup. Ct. Iowa, Apr. 9, 2010).
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