Missouri Court of Appeals, Western District / Jun 25, 2019
Cindy Lockhart, et al vs. Susan Carlyle
Cindy and Dennis Lockhart sued Susan Carlyle for the wrongful death of their son, Tyler Lockhart, alleging negligent entrustment of a vehicle to Carlyle's adult son, Richard Gallagher. The trial court granted summary judgment for Carlyle, finding she did not entrust the vehicle. The appellate court affirmed, holding that merely providing financial assistance for a vehicle's purchase, without ownership or control, does not constitute entrustment. The court also rejected a general negligence claim, stating that a parent-adult child relationship alone does not create a duty to protect third parties.