CACI No. 720

[Name of plaintiff] claims that [he/she/ nonbinary pronoun] was harmed

and that [name of defendant] is responsible for the harm because [name of

defendant] gave [name of driver] permission to operate the 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] was an owner of the vehicle at the time

of the injury to [name of plaintiff]; and

3. That [name of defendant], by words or conduct, gave permission to

[name of driver] to use the vehicle.

In determining whether permission was given, you may consider the

relationship between the owner and the operator. [For example, if the

parties are related or the owner and the operator are employer and

employee, such a relationship may support a finding that there was

implied permission to use the vehicle.]

[If the vehicle owner has given a person permission to use the vehicle,

and that person authorizes a third person to operate the vehicle, the

third person may be considered to have used the vehicle with the

permission of the owner.]

New September 2003