Young v. Beck
227 Ariz. 1
Ariz.2011Background
- Kenneth and Barbara Beck furnished a sport utility vehicle to their seventeen-year-old son Jason, who was the primary driver.
- Jason used the vehicle for school, church, work, and social purposes with parental permission, but the Becks restricted transporting friends.
- Approximately one month later, Jason requested to drive to a friend's house after work; his mother permitted it under the understanding he would stay there and return the next day.
- Jason violated the restriction by driving with friends, dropping off a girlfriend, and then colliding with Amy Young, causing serious injuries.
- Young sued Jason and named the Becks, arguing vicarious liability under the family purpose doctrine; the Becks settled to a high-low agreement and the matter advanced on appeal.
- The Arizona Supreme Court granted review to assess whether the family purpose doctrine remains viable, given UCATA and policy considerations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does UCATA abrogate the family purpose doctrine? | Young: UCATA supersedes the doctrine by eliminating joint liability. | Becks: UCATA preserves only certain vicarious notions; agency-based abrogation applies. | UCATA does not abrogate the doctrine. |
| Should the court abolish the family purpose doctrine altogether? | Doctrine serves compensatory policy and utility for injured victims. | Doctrine is outdated, unfair, and should be abandoned. | Court declines to abolish the doctrine. |
| Did the trial and appellate courts correctly apply the doctrine as a matter of law on undisputed facts? | Permission existed and the driver’s use fit family purpose despite deviations. | Driver’s use violated restrictions, so doctrine should not apply. | Doctrine applies; Young entitled to summary judgment on applicability. |
Key Cases Cited
- Benton v. Regeser, 20 Ariz. 273 (1919) (adopted family purpose doctrine for vicarious liability)
- Mortensen v. Knight, 81 Ariz. 325 (1956) (agency test referenced in family purpose context)
- Jacobson v. Superior Court (Steinhoff), 154 Ariz. 430 (App. 1987) (doctrine serves practical purpose beyond traditional agency)
- Wiggs v. City of Phoenix, 198 Ariz. 367 (2000) (UCATA did not abolish non-delegable vicarious liability doctrine)
- Premier Manufactured Systems, Inc., 217 Ariz. 222 (2007) (distinguished from Wiggs on product-liability context; UCATA scope)