CACI 724. Negligent Entrustment of Motor Vehicle

[Name of plaintiff] claims that [he/she/nonbinary pronoun] was harmed because [name of defendant] negligently permitted [name of driver] to use [name of defendant]’s vehicle. To establish this claim, [name of plaintiff] must prove all of the following:

  1. That [name of driver] was negligent in operating the vehicle;
  2. That [name of defendant] [owned the vehicle operated by [name of driver]/had possession of the vehicle operated by [name of driver] with the owner’s permission];
  3. That [name of defendant] knew, or should have known, that [name of driver] was incompetent or unfit to drive the vehicle;
  4. That [name of defendant] permitted [name of driver] to drive the vehicle; and
  5. That [name of driver]’s incompetence or unfitness to drive was a substantial factor in causing harm to [name of plaintiff].