Conn. Civ. Jury Instr. 3.6-17

The plaintiff has sued the defendant for negligent entrustment. In Connecticut. a person may be

sued for negligently entrusting <identify property> to another.

To find a defendant liable for negligent entrustment, you must find that the defendant allowed a

third person to use property under the control of the defendant, when the defendant knows or

should know that such person intends or is likely to use the property in such a manner as to

create an unreasonable risk of harm to others. One who supplies <identify property> for the use

of another whom the defendant knows or should know is likely because of his youth,

inexperience, or otherwise, to use it in a manner involving unreasonable risk of physical harm is

subject to liability for the resulting physical harm.

Liability for negligent entrustment is founded on the right and power of a defendant to permit or

prohibit the use of the <identify property>. A person can exercise that degree of control only if

that right to control is exclusive or, if not, then superior to any coexisting right of control held by

the entrustee or by a third party. Moreover, liability cannot be imposed on a defendant under a

theory of negligent entrustment simply because the defendant permitted another person to use the

<identify property>.

In order to prove negligent entrustment, the plaintiff must demonstrate that:

1. the defendant had a superior right of control over the <identify property> such

that

the defendant could permit or prohibit the use of the <identify property>;

2. the defendant entrusted the <identify property> to the person who used the

<identify property> in such a way as to cause harm;

3. the defendant knew or had reason to know that <name of person causing harm>

intended or was likely to use the <identify property> in a manner that involved

unreasonable risk of physical harm; and

4. such use did in fact cause harm to the plaintiff.