Second Child v. Edge Auto, Inc.

Summary

The court held that federal law preempts New York's requirement that rental car companies provide primary liability insurance coverage to renters for damages caused solely by renters' negligence. It held that the federal law does not preempt New York's separate requirement that rental companies maintain specified minimum insurance or financial-responsibility coverage. The court also held that the federal law is not reverse-preempted under the McCarran-Ferguson Act because the remaining conflict concerns vicarious liability rather than the business of insurance.