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An example of a minimum requirement statutes found in NY Ins. ACT 3420 (f) (1) (McKinney 1985), which states:

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No insurance against losses arising from liability provided by law for bodily injury or death by natural persons from the ownership, maintenance and operation of a motor vehicle by the insured or by an authorized insurer in any motor vehicle then principally used or principally garage in this state, unless it contains a provision requiring the insurer explained that he pays to the insured, as defined in these rules, subject to the terms and conditions to be there, by the Board of Directors of the Motor Accident Compensation Corporation and by the director, all sums, up to a maximum of ten thousand or U.S. Dollar, plus interest and costs, due to injuries and all sums, up to a maximum amount or limit of fifty thousand excluding interest and costs resulting from the death of a person in an accident, and a maximum amount or limit, if such a person so injured by twenty thousand U.S. dollars or killed, according to the hundred thousand dollars, excluding interest and costs.

8See Jackson v. Citizens Cas. Co., 14 NE2d 446 (NY 1938); Lavine v. Indemnity Ins. Co., N. Am., 183 N.E. 897 (NY 1933); Skenandoa Rayon Corp. v. Halifax Fire Ins. Co., Halifax, Nova Scotia, 3 NE2d 867 (NY App. Div. 1935).

9Typically under an omnibus account clause, a person, the automobile policy extends coverage to people involved in the car owned by an insured person by the name of the express or tacit consent of the latter. See About v. Ohio Cas. Ins. Co., 55 Cal. Rptr. 720 (Ct. App. 1967).

"oClauses, as in this case gave rise to many disputes between insurers and car rental personal lines, who should be primarily responsible. illustrate this point is Mercury CAS. Co. v. Hertz Corp., 69 Cal. Rptr.2d 9 (Ct. App. 1997). "" An example of such a clause, see Irvin v. Rhodes, 929 SW2d 829 (Mo. Ct. App. 1996).

"" See Morris v. Snappy Car Rental, Inc., 637 NE2d 253 (NY 1994).

13Miller v. Sullivan, 174 Misc.2d 690, 692-93 (NY sup. Ct. 1997). '4 It is extracted from Enterprise Rent-A-Car agreement used in the State of New York. On file with the authors.

'5 So far, the following states / counties have agents liability statutes on their books: Connecticut, District of Columbia, Florida, Idaho, Iowa, Maine, Michigan, Minnesota, New York and Rhode Iceland.

'6 See Irvin v. Rhodes, 929 SW2d 829 (Mo. Ct. App. 1996) (insurer unsuccessfully argued against his landlord statutory duty, are adequately insured by the primary liability for the tenant).

"" An example of this type of statute is located in Missouri, which states: No owner of a motor vehicle in this state must have the vehicle, or any other person authorized to operate the vehicle unless the owner claims the financial responsibility, as provided in this section. Moreover, no person shall be a motor vehicle owned by another with the knowledge that the owner does not retain the financial responsibility, unless that person has the financial responsibility of its operation of the other vehicle.