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It is clear that under New York law, a car is not required by law or in other ways to expand insurance coverage to its tenants, or permissive user. New York court's findings were consistent on this issue.97

11. New Jersey

New Jersey employs a different approach than that of New York. In Kattoura V. Patel, 9s the New Jersey court found that the state statutory scheme, car rental companies, the insurance for the tenant, although there is no requirement that the insurance only with the primary partitions. On the court, a state statute99 to require that a rental car company get liability coverage on their vehicles are not sufficient, landlords and tenants of rental cars and insurance, to agree that the insurance will be a party primary and the other on. 100

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Applying this logic, the Court held that the secondary liability provision clearly to the alleged minimum insurance requirements, but only in an excess capacity, if the tenant had multiple other primary products, the provision was valid because it is not contrary to state statutes. A similar result was in Rogers v. Snappy Car Rental, Inc.101 To make a determination of the primary coverage was based on the interaction of the tenant's other insurance clause and the secondary liability provision.

12. Colorado

In Allstate Insurance Co. v. Avis Rent-A-Car,'2 Colorado court, in relation to a claim for damage to a secondary liability provision in the Avis rental agreement was in fact an insurance provision, which purported Avis to more about their tenant's personal liability coverage.l03 In the coming of this provision, the court may review the provisions of the tenant insurance,'4 and compared them with the Avis secondary liability provision. She came to the conclusion that the two "coverages that are significantly similar clauses to force the insurance to other insurers to respond as the primary insurer. "" 'O5 As a result, since both provisions are applied, the Court held that public policy in order both to be mutually exclusive.'6

In order to tackle the issue of liability, the Court held that the liability between Avis and the insurer to be in proportion with each contributing to the ultimate liability.'07 It is interesting to note that the court, when the Avis clause in the nature of an excess insurance clause, in contrast to a shift of liability provision. The court further noted that the Colorado insurance provisions'8 order that each motor vehicle owner to obtain liability coverage.

The Court's decision is not entirely clear whether the state statute requires the extension of the rental car company insurance to its tenants. The impact from the decision is that it is exactly what the Court considers that the two operate Avis and had mutually exclusive Allstate insurance provisions.

13. Vermont