California, United States of America
The following excerpt is from Blake v. Moore, 162 Cal.App.3d 700, 208 Cal.Rptr. 703 (Cal. App. 1984):
Not so long ago the "guest statute" immunized drivers, and those vicariously responsible for them, from liability to their guests who were injured as a result of negligent driving. In a classical legal analysis, Justice Tobriner distinguished the liability of a mother resulting from her daughter's negligent driving (the vicarious liability immunized by the guest statute) and the liability which arose because of the entrustment of the vehicle to an unfit driver. (Nault v. Smith (1961) 194 Cal.App.2d 257, 14 Cal.Rptr. 889.) He illustrated the distinction:
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