In Covey Drive Yourself & Garage v. Portland, 157 Ore. 117, 70 P.2d 566 (1937), the city passed an ordinance regulating car rentals. The ordinance required the businesses to be licensed by the city; to post a surety bond or liability insurance policy of $ 1,000; and to agree that the bond or insurance would indemnify persons injured by the negligence of anyone renting cars from the licensed rental agent. Covey Drive Yourself & Garage, 157 Ore. at 120-21. Further and significantly, the ordinance provided that anyone injured, or the heirs of anyone killed, by a driver's negligence would be authorized to bring an action against the licensee, the surety, or the insurer for damages. The plaintiff, a rental and repair business, brought an action seeking to invalidate the ordinance on the grounds that vehicle regulation was preempted by state law and that the ordinance's provisions were otherwise beyond the city's regulatory power. The court held that the city's ordinance was not preempted by state law because it was a complementary enactment that sought to achieve the same goals by "different methods." Id. at 125. With regard to the plaintiff's challenge to the liability provisions, the court observed that the purpose of creating liability was "to coerce the renter into renting his cars only to those who will drive with care." Id. at 128. The court considered it "a matter of common knowledge that a consciousness of financial responsibility for negligence tends to promote care, and, conversely, that a consciousness of financial irresponsibility tends to promote indifference." Id. at 130. In Covey Drive Yourself & Garage v. Portland, the ordinance provided, in part: "'The cash deposit, the surety bond, or the insurance policy, shall each be conditioned that the licensee, his surety or insurer, will pay any adjudicated claim within the limit of the liability of $ 1,000 ten days after the date of the final adjudication of any claim. The cash deposit, the surety bond or the liability insurance shall be further conditioned that the licensee and the surety or insurer will be liable for injury to or the death of any person and for damages to the property of any person caused by the carelessness, negligent or unlawful act of the driver of the vehicle rented or hired out. The liability of said cash deposit, said surety bond or liability insurance shall not exceed the sum of $ 1,000 arising out of any one accident: Any person sustaining personal injuries or property damage caused by the carelessness, negligent or unlawful act of the driver of any motor vehicle rented or hired out under the terms of this article; or in case of death resulting from personal injuries, the personal representative of the deceased, is hereby authorized to institute an action against the licensee, the surety, or against the liability insurance company on his own relation in the name of the city and to prosecute the same to final judgment.'" 157 Ore. at 120-21. In determining that the standard imposed by the ordinance was a valid exercise of the city's police power, the court reasoned: "The enactment of an ordinance or of a statute -- unless they be merely codifications of existing regulations -- necessarily alters the existing law. Ordinarily, the violation of such a regulation constitutes negligence per se when applicable in civil actions. In other words, the enactment of the ordinance affects the common law by prescribing a different standard of conduct." Id. at 139. As to the remedy for the enforcement of the standard imposed by the ordinance, the court stated that the ordinance was a form of voluntarily-incurred contractual liability. "It may be avoided by avoiding the driverless car business; but, as a condition of entering the business, the bond must be filed. The liability attends upon the bailment even though the negligent injury is inflicted in some distant state. It is enforced in the remote place, not because Portland's authority extends there, but because the other state will enforce the contractual liability in its courts." Id. at 140. Thus, Covey stands for the unremarkable proposition that a municipality may create liability between its citizens that may be enforced in a state court in accordance with an already available remedy.