Johnson v. Avis Rent a Car System, LLC (two Cases)

Summary

The Supreme Court of Georgia affirmed judgments for the defendants in both cases, holding that Perry's intervening criminal conduct was the sole proximate cause of the plaintiffs' injuries as a matter of law. The evidence did not show that a high-speed chase and resulting injuries were a probable or natural consequence that the defendants could reasonably have foreseen from the negligent failure to secure the rental vehicle. The court also held that Perry was not acting under color of employment when he stole the vehicle and injured Smith, although it rejected the Court of Appeals' reasoning that acting against the employer's interests defeats that element.