Bruce Kyle Emerson v. Kyle Michael Lambert

Summary

The court answered the certified question no, holding that a family member who is a bailee of a vehicle is not additionally vicariously liable under Florida's dangerous instrumentality doctrine when another family member is the acknowledged title owner and is already vicariously liable for the same entrustment. The court reasoned that liability generally follows legal title or another qualifying property interest, but the doctrine does not multiply liability among family members who share a vehicle, and allowing cumulative liability would circumvent statutory limits. The court affirmed the decision below to the extent consistent with its opinion.