BILL ANALYSIS                                                                                                                                                                                                    






                             SENATE JUDICIARY COMMITTEE
                           Senator Ellen M. Corbett, Chair
                              2009-2010 Regular Session


          AB 2059 (Calderon)
          As Amended June 14, 2010
          Hearing Date: June 22, 2010
          Fiscal: No
          Urgency: No
          SK:jd
                    

                                        SUBJECT
                                           
                              Vehicle Rental Agreements

                                      DESCRIPTION  

          This bill would require a rental car company that enters into a  
          vehicle rental agreement with a renter who is not a resident of  
          this country to do the following when that renter purchases  
          supplemental liability insurance as part of the agreement: (1)  
          accept service of process of any complaint against the renter  
          regarding harm, loss, or damage related to the use or operation  
          of the rental car; and (2) mail a copy of the summons and  
          complaint to the renter.  This bill, which would provide this  
          mechanism for service of process only where the plaintiff agrees  
          to limit his or her recovery to the limits of protection  
          provided by the insurance, would sunset on December 31, 2013.

                                      BACKGROUND  

          Existing law provides that in certain instances an individual is  
          deemed to have consented to the appointment of another entity to  
          serve as his or her agent for service of process.  For example,  
          under the Vehicle Code, out-of-state drivers impliedly consent  
          to the appointment of the Department of Motor Vehicles' director  
          as their agent for service of process in any action against that  
          nonresident driver for injuries caused by an accident or  
          collision.  Similarly, this bill, sponsored by the Consumer  
          Attorneys of California, would require a rental car company to  
          accept service of process for out-of-country renters when those  
          renters purchase supplemental liability insurance as a part of  
          the vehicle rental agreement. 

                                                                (more)



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                                CHANGES TO EXISTING LAW
           
           Existing law  specifies restrictions on rental vehicle agreements  
          and regulates a renter's liability for loss due to theft, a  
          rental company's loss of use, damage, or loss to the car, damage  
          waivers and damage waiver fees.  (Civ. Code Sec. 1936.)

           Existing law  provides that a rental car company may act as a  
          rental car agent for an authorized insurer in connection with  
          liability insurance, which may include uninsured motorist  
          coverage, that provides coverage to the renter and is not  
          duplicative of any standard liability coverage, for liability  
          arising from the negligent operation of the rental vehicle.   
          (Ins. Code Sec. 1758.85(b).)

           Existing law  provides that a nonresident driver impliedly  
          consents to the appointment of the director of the Department of  
          Motor Vehicles (DMV) as his or her agent for service of process  
          in any action against the nonresident driver for injuries caused  
          by an accident or collision.  Existing law provides that service  
          of process shall be made by delivering a copy of the summons and  
          complaint to the director.  The plaintiff must also send a copy  
          of the summons and complaint by registered mail to the  
          nonresident driver, return-receipt requested.  (Veh. Code Secs.  
          17451, 17454, 17455, 17456.) 

           This bill  would require a rental car company that enters into a  
          vehicle rental agreement with a renter who is not a resident of  
          this country to do both of the following when that renter  
          purchases supplemental liability insurance, as defined in  
          Insurance Code Section 1758.85(b), as part of the agreement: 

             1.  accept service of process of any complaint against the  
              renter regarding harm, loss, or damage related to the use or  
              operation of the rental car.  Process may be served by  
              first-class mail, return receipt requested, or by personal  
              service by a registered process server; and 

             2.  provide a copy of the summons and complaint to the renter  
              by first-class mail, return receipt requested.  

           This bill  would provide the above-described mechanism for  
          service of process only where the plaintiff agrees to limit his  
          or her recovery to the limits of protection provided by the  
          insurance. 

                                                                      



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           This bill  would sunset on December 31, 2013.
                                           
                                       COMMENT
           
          1.  Stated need for the bill  
          
          The author writes:
          
            Rental car companies sell various types of insurance and  
            waivers.  Loss damage waivers (LDW) and collision damage  
            waivers (CDW) from the rental company essentially take the  
            place of the renter's own collision and comprehensive  
            insurance.  Some LDWs include CDW and some waivers require  
            payment of a deductible.  These types of insurance sales are  
            very profitable for a car rental company.  Avis, for example,  
            sells five kinds of coverage and about 30% of renters at  
            Enterprise Rent-A-Car buy some type of insurance coverage.   
            According to a 2007 National Association of Insurance  
            Commissioners (NAIC) study, 34% of consumers surveyed bought a  
            rental car company's insurance.  Further, according to a  
            national auto rental consultant, sales of insurance are an  
            "important profit center" for car rental companies.  . . .  

            However when a non-California resident who rents a car causes  
            a car accident and injures a California resident it can be a  
            nightmare for the California resident to try to locate the car  
            renter and seek remedial action.  For example, in San  
            Francisco, a Tibetan rented a car and purchased the insurance  
            sold by that company.  The Tibetan caused a major accident,  
            leaving a California resident severely injured, and left the  
            US.  In this case, the plaintiffs actually had to hire a yak  
            to get to the location of service.  In another actual case  
            from Northern California, a CAOC member is representing a  
            police officer who was on duty riding his department issued  
            motorcycle when he was injured by a German Tourist who made an  
            illegal turn causing the officer to hit and flip over the  
            tourist's rental car.  The expense and difficulty of complying  
            with the Hague convention [See Comment 4b] would cause a  
            serious burden to the police officer's recovery.  . . .  The  
            losers in the current situation are Californians who are  
            injured or killed by an out-of-state renter because the case  
            cannot proceed unless the defendant is properly served.  The  
            State of CA suffers as well because if the defendant cannot be  
            served and the case not processed, the medical bills may often  
            end up being paid by California taxpayers.

                                                                      



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          Sponsor Consumer Attorneys of California (CAOC) writes that the  
          bill will help Californians because the service of process  
          requirements under the Hague Convention are "onerous obstacles  
          [which] can be avoided if the rental company simply accepts  
          service of process on behalf of its renter."  CAOC also points  
          out that:

            [w]hen service of process cannot be accomplished, often  
            California suffers financially as well.  If the defendant  
            cannot be served and the case not processed, the medical bills  
            may often end up being paid by California taxpayers.  Under  
            the normal course of a lawsuit, the medical bills would be  
            repaid out of the lawsuit recovery to the state in instances  
            where it provides medical care.  However, under the current  
            situation, if a defendant cannot be served, he or she (and the  
            insurer) avoid responsibility and the victim and the state end  
            up paying.

          2.  Recent amendments narrowed the bill  
          
          The author recently amended this bill to narrow its provisions  
          in several ways.  First, this bill had previously required a  
          rental car company to accept service of process for out-of-state  
          renters.  The bill has been amended to now impose that  
          requirement only as to renters who are not residents of this  
          country.  The bill also previously would have required the  
          rental car company to accept service of process for authorized  
          drivers, in addition to the renter.  The most recent amendments  
          deleted "authorized drivers" in response to concerns that  
          California law automatically authorizes a renter's spouse or  
          co-worker to drive the rental car, and the rental car company  
          may not know that individual's identity.  The bill was also  
          amended to clarify that "supplemental liability insurance" means  
          liability insurance as defined in Insurance Code Section  
          1758.85(b).  The most recent amendments also deleted a notice  
          requirement that appeared to be unnecessary and inserted a  
          sunset date of December 31, 2013. 

          3.  Bill would require rental car companies to accept service of  
            process for out-of-country renters  
          
          This bill would require a rental car company to accept service  
          of process for out-of-country renters who purchase supplemental  
          liability insurance as a part of the vehicle rental agreement.   
          The bill would also require the rental car company to mail a  
          copy of the summons and complaint to the renter, return receipt  
                                                                      



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          requested. 

              a.   Accepting service of process for out-of-country renters;  
               plaintiff's recovery limited 
              
            This bill would require a rental car company to accept service  
            of process for out-of-country renters and would specify that a  
            plaintiff who elected to serve the renter in the manner  
            prescribed by the bill would be limited in his or her recovery  
            against the renter or the rental company to the limits of the  
            protection extended by the supplemental liability insurance.  

            Under this bill, the plaintiff would serve on the rental car  
            company the summons and complaint against the out-of-country  
            renter by first-class mail, return receipt requested.  Once  
            service of process requirements are met in this way, the  
            plaintiff would be able to bring his or her claim against the  
            supplemental liability insurance policy in order to recover. 

              b.   Supplemental liability insurance  

            This bill's requirement that a rental car company accept  
            service of process for out-of-country renters applies when  
            that renter has purchased supplemental liability insurance as  
            a part of the vehicle rental agreement.  The most recent  
            amendments to the bill define supplemental liability insurance  
            as defined in Insurance Code Section 1758.85(b) which provides  
            that a rental car company may act as a rental car agent for an  
            authorized insurer in connection with liability insurance,  
            which may include uninsured motorist coverage, that provides  
            coverage to the renter and is not duplicative of any standard  
            liability coverage, for liability arising from the negligent  
            operation of the rental vehicle.  

            That amendment defining supplemental liability insurance  
            pursuant to Insurance Code Section 1758.85(b) makes clear that  
            the insurance coverage referenced in the bill is the coverage  
            purchased from the rental car company as part of the vehicle  
            rental agreement rather than the renter's own automobile  
            insurance policy. 

            Rental car companies offer supplemental liability insurance  
            policies at an additional cost which varies, depending on the  
            company.  In one case, the charge for supplemental liability  
            insurance for a recent rental would be $11.99 per day.   
            Another company charged $14.80 per day.  These policies  
                                                                      



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            generally cover up to $1 million for third party liability  
            claims, although at least one company provides coverage up to  
            $2 million, depending on the location.

           c.Requirement to mail summons and complaint to the renter

           Opponents Avis Budget Group and Hertz Corporation assert that  
            the bill's requirement that rental car companies provide a  
            copy of any summons and complaint served to the renter by  
            first class mail "creates significant liability exposure for  
            the rental car company if it does not succeed in providing a  
            copy of the summons and complaint to the driver."  The Civil  
            Justice Association of California makes similar arguments.   

          It does not appear, however, that the bill would require a  
            rental car company to do anything more than provide a copy of  
            any summons and complaint served on the company to the  
            out-of-country renter by first-class mail, return receipt  
            requested.  The rental car company is in the best position to  
            be able to forward the summons and complaint to the renter  
            since the company has the renter's contact information (and  
            the plaintiff likely does not).  And, as long as the company  
            mailed to the renter the summons and complaint, the company  
            would be in compliance with the statute.  

          In addition, the bill specifically provides that the requirement  
            that the rental car company accept service of process shall  
            not create any duty, obligation, or agency relationship other  
            than the responsibility to provide the summons and complaint  
            to the renter. 

          Avis Budget Group additionally argues that this bill raises due  
            process concerns because a defendant may not receive notice of  
            the action.  Specifically, Avis asserts that the service of  
            process proposed by the bill is not "reasonably calculated to  
            give actual notice." 

          Because it appears that return receipt is available only to  
            certain countries, the Committee should amend the bill to  
            provide that service by the rental car company may also be  
            made by registered mail.  The following amendment, which would  
            help to address the due process concern mentioned above, would  
            achieve this:

                Suggested amendment:

                                                                      



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                On page 18, line 13, after "requested" insert "or  
               registered mail."












































                                                                      



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          4.  Existing service of process mechanisms  
          
           a.Vehicle code provisions  

          Under existing law, a nonresident driver impliedly consents to  
            the appointment of the director of the DMV as his or her agent  
            for service of process in any action against the nonresident  
            driver for injuries caused by an accident or collision.  (Veh.  
            Code Sec. 17451.)  "Nonresident" is defined as a person who is  
            not a resident of California at the time of the accident or  
            collision.  (Veh. Code Sec. 17450.)  Service must be made upon  
            the director, and a notice of service and a copy of the  
            summons and complaint must be sent by registered mail to the  
            defendant.  (Veh. Code Secs. 17454, 17455.)  A return receipt  
            is required to show proof of compliance.  (Veh. Code Sec.  
            17456.)    

            Opponents Avis Budget Group and Hertz Corporation argue that  
            this bill is therefore unnecessary because these Vehicle Code  
            provisions "already [authorize] the DMV director to accept  
            service of process for nonresident drivers."  The sponsor  
            points out, however, that the U.S. Postal Service does not  
            accept return receipts for many international deliveries so  
            plaintiffs may not use these code sections in those instances.  
             In addition, even if the Postal Service did accept return  
            receipts in all cases, the Vehicle Code provisions still  
            impose difficult burdens on the plaintiff because they require  
            that a copy of the  summons and complaint be sent by  
            registered mail to the nonresident renter.  This requires that  
            the plaintiff know the renter's address, which may only be  
            accessible from the rental car company's records.    

           b.Hague Convention of 15 November 1965 on the Service Abroad of  
            Judicial and  
               Extrajudicial Documents in Civil or Commercial Matters  
            (Hague Convention)

               The author and his sponsors assert this bill is necessary  
            because "[s]ervice of process on out of country defendants is  
            complicated, expensive, and difficult as (1) the onerous  
            provisions of the Hague Convention of 1965 On the Service  
            Abroad of Judicial and Extrajudicial Documents in Civil or  
            Commercial Matters must be met; (2) not all countries have  
            agreed to the Hague Convention; (3) the paperwork must be  
            translated into the language of the defendant; and (4) a  
            service processor must be located."  Legal commentators have  
                                                                      



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            also noted the complexity of serving international defendants.  
             (See, e.g., Comment, Dysfunctional Equivalence: The New  
            Approach to Defining "Postal Channels" Under the Hague Service  
            Convention, (2007) 55 UCLA L. Rev. 205; Greenwood, Serving  
            Them Right: When Taking on International Defendants, Expect  
            Challenges, Even Complications, (2005) 91 A.B.A.J. 24.)

              One supporter describes a case "in which a Denmark resident  
            caused my client to suffer a serious injury as a result of  
            negligent driving of a vehicle that was rented here in  
            California.  The Denmark driver purchased bodily injury  
            liability insurance through the rental company.  The insurance  
            company knows of the bodily injury and the negligence that  
            caused my client to suffer damages.  The insurance company  
            will eventually cover the loss, however, the insurance company  
            is refusing to even negotiate on the claim unless and until we  
            effect service of process on the driver in Denmark.  This has  
            unnecessarily delayed the claim, which is causing additional  
            damages to my client, and that is preventing other companies  
            here in California to be reimbursed for medical expenses that  
            they incurred as a result of the Denmark driver's negligence.   
            Moreover, this has caused an unnecessary lawsuit to be filed,  
            just so that we can effect service in Denmark complying with  
            the Hague Service Convention.  Furthermore, we will incur  
            substantial additional cost and delay as a result.  All of  
            this would have been unnecessary if your [b]ill had already  
            been the law."  

              By requiring rental car companies in certain instances to  
            accept service of process for international renters, this bill  
            implicates service of process outside of the United States.   
            Both California law and the Hague Convention govern the  
            transmission of documents outside the United States.  In  
            addition, under the Supremacy Clause (U.S. Const. Art. VI),  
            the Hague Convention preempts any inconsistent state laws.   
            (Volkswagenwerk Aktiengesellschaft v. Schlunk (1988) 486 U.S.  
            694.)  There are currently 61 countries, or "Contracting  
            States," that are parties to the Hague Convention, which  
            "deals primarily with the transmission of documents; it does  
            not address or comprise substantive rules relating to the  
            actual service of process."  (Outline, Hague Service  
            Convention, Hague Convention of 15 November 1965 on the  
            Service Abroad of Judicial and Extrajudicial Documents in  
            Civil or Commercial Matters,  
             http://www.hcch.net/upload/outline14e.pdf  .)  Contracting  
            States may opt out of one or more forms of service. 
                                                                      



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               California law provides that, except as otherwise provided  
            by statute, a summons shall be served on a person outside the  
            United States as provided in the Code of Civil Procedure, as  
            directed by the court in which the action is pending, or, if  
            the court before or after service finds that the service is  
            reasonably calculated to give actual notice, as prescribed by  
            the law of the place where the person is served or as directed  
            by the foreign authority in response to a letter rogatory.   
            (Code Civ. Proc. Sec. 413.10.)  These rules are subject to the  
            provisions of the Hague Convention.  (Id.)   

              While the rules governing service of summons outside of the  
            United States are subject to the provisions of the Hague  
            Convention, depending on the receiving country, it would  
            appear that this bill's provisions requiring rental car  
            companies to mail a copy of the summons and complaint to the  
            out-of-country renter would likely meet service requirements.   
            The sponsor provides the following rationale: 

               . . .  AB 2059 provides for an agent for service of process  
               within the United States (rental car company);  therefore,  
               the Hague Convention is not the exclusive means of service.  
                [Also] AB 2059 is not inconsistent with the Hague  
               Convention.  AB 2059 seeks to facilitate service of process  
               abroad.  The Hague Convention "was formulated in 1964-65 by  
               delegates from the United States and 22 other nations?.with  
               the original intent to help ensure that defendants sued in  
               foreign jurisdictions would receive actual and timely  
               notice of suit and to facilitate proof of service abroad."  
               (citations omitted)  The U.S. Supreme Court has stated  
               that: "We do not think that any country will draft its  
               internal laws deliberately so as to circumvent the  
               Convention in cases in which it would be appropriate to  
               transmit judicial documents for service abroad?we  
               anticipate that parties may resort to the Convention  
               voluntarily, even in cases that fall outside the scope of  
               its mandatory application." (Volkswagenwerk at  705-706.)   
               AB 2059 is consistent with the intent and with the express  
               language of the Convention.

          5.  Opposition  
          
          The California Chamber of Commerce writes in opposition to the  
          measure:

                                                                      



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            [This bill] would shift the responsibility and cost of  
            notifying the renter  . . .  from the plaintiff to the car  
            rental company, regardless of the burden posed to the  
            plaintiff in notifying the particular driver  . . .  So long  
            as plaintiffs expect that their recovery will be within the  
            limits of the insurance coverage, they will happily pass on  
            the burden and expense of locating and notifying renters  . .  
              .  regardless of whether the plaintiff is actually in a better  
            position to locate the driver, and regardless of whether  
            notification would pose a significant burden for the plaintiff  
            at all.  This is an unreasonable burden that goes  
            significantly beyond what is necessary to address the  
            scenarios offered by the sponsor as justification for the  
            bill.  . . .  Neither the bill sponsor nor the author cite any  
            evidence to support the assertion that insurance sales are  
            "very profitable" for car rental companies.  To the extent  
            that car rental companies price their policies reasonably to  
            address their risks, while keeping them affordable so that  
            renters take advantage of the coverage, they will need to  
            raise rates to compensate for increased exposure and the costs  
            associated with having to identify and notify drivers far and  
            wide.  

          6.  Technical amendments needed  
          
          The following technical correction amendments are needed:

            On page 18, line 12, delete "(B)" and insert "(A)"

            On page 18, line 23, delete "(B)" and insert "(A)"

            On page 18, line 25, delete ", authorized driver," 

            On page 18, line 26, delete "coverage, benefit, or insurance"  
            and insert "supplemental liability insurance"

           









                                                                      



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          Support  :  One individual 

           Opposition  :  Avis Budget Group; California Chamber of Commerce;  
          Civil Justice Association of California; Hertz Corporation  
                                           
                                       HISTORY
           
           Source  :  Consumer Attorneys of California 

           Related Pending Legislation  :  None Known 

           Prior Legislation  :  None Known 

           Prior Vote  :

          Assembly Judiciary Committee (Ayes 7, Noes 3)
          Assembly Floor (Ayes 48, Noes 28)

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