Malco Enter. of NV, Inc. v. Woldeyohannes, 140 Nev. Adv. Op. 76 (Dec. 5, 2024)

Under NRS 482.305, short-term lessors of motor-vehicles who fail to provide lessees with minimum insurance coverage are held jointly and severally liable. By contrast, the Graves Amendment, a federal statute, bars states from holding lessors vicariously liable absent a showing of negligence. Respondent, Alelign Woldeyohannes, was rearended by Daniel Moore, who was intoxicated while driving a rental car. Alelign sued both Daniel for damages and the owner of the rental car company, Malco Enterprises of Nevada, Inc., for negligent entrustment. Following a default judgment against Daniel and a subsequent request for a de novo trial, the short trial judge entered a default judgment against both Daniel and Malco. The district court agreed and entered a final judgment consistent with the short trial judge. Appellant appealed to the Nevada Supreme Court challenging the district court’s interpretation of federal preemption. The Justices unanimously upheld the district court’s judgment because case precedent supports the court’s interpretation and NRS 482.305 is preserved under the savings clause.