“Plaintiff claims that he was harmed because Defendant negligently permitted the driver to use Defendant’s vehicle. To establish this claim, Plaintiff must prove all of the following: 1. That the driver was negligent in operating the vehicle; 2. That Defendant owned the vehicle operated by the driver/had possession of the vehicle operated by the driver with the owner’s permission; 3. That Defendant knew, or should have known, that the driver was incompetent or unfit to drive the vehicle; 4. That Defendant permitted the driver to drive the vehicle; and 5. That the driver’s incompetence or unfitness to drive was a substantial factor in causing harm to Plaintiff.”
[CACI Jury Instructions [citations omitted]]
