Is the Individual Who Possesses Legal Title of a Motor Vehicle Vicariously Liable In the Event of An Accident ?

In Metzel v. Robinson, 102 So. 2d 385, 385-86 (Fla. 1958), the Court made it clear that, absent a conditional sales agreement, the circumstances where an entity or individual who possessed legal title would not be vicariously liable under the dangerous instrumentality doctrine were extremely limited. In Metzel, a nephew caused injuries to the plaintiff by negligently operating a motor vehicle, which was titled in his aunt's name. See id. at 385. The plaintiff sued the aunt, the record title holder of the vehicle, under the dangerous instrumentality doctrine. See id. According to the facts, the aunt had taken title to the vehicle only to assist her nephew in purchasing and financing the vehicle. See id. The nephew took possession of the vehicle after its purchase, and the aunt had nothing more to do with the vehicle. See id. Nevertheless, because the aunt took no action to divest herself of title to the car, the Court determined that she was the "owner" of the automobile as a matter of law. See Metzel, 102 So. 2d at 385-86. In making this determination, the Court further explained that the aunt was "still in a position to exert some dominion and control over the vehicle." Id. at 386. Thus, because the aunt held title to the vehicle and could exercise dominion and control over the vehicle, the Court concluded as a matter of law that the aunt would be held vicariously liable under the dangerous instrumentality doctrine. See id. at 386.