The family car doctrine is not as straightforward as it sounds. It extends beyond family members, and imputes liability on those who are not merely the title holder of the car. This article explores the boundaries of the family car doctrine as it currently exists in Connecticut jurisprudence: (1) who is a “family” member under the doctrine? and (2) who is a proper defendant for vicarious liability under the doctrine?

The family car doctrine found its beginnings in Connecticut jurisprudence in 1919. In Wolf v. Sulik, 93 Conn. 431 (1919) a plaintiff was injured when his wagon was struck by a car. The car was owned by the defendant-wife and being driven by her husband. The Connecticut Supreme Court upheld the trial court's judgment holding the wife vicariously liable for the husband's negligence. In so doing, the court relied on the principals of respondeat superior. The court held that because the wife purchased the car for the pleasure and convenience of her husband, she was liable for his negligent acts.

Four years later, the Connecticut Supreme Court formally adopted the family car doctrine into the common law. See Stickney v. Epstein, 100 Conn. 170 (1923). There, the court announced “when a motor-car is maintained by the paterfamilias for the general use and convenience of his family, he is liable for the negligence of a member of the family having general authority to drive it, while the car is being used as a family car.” The court went on to clarify that when a household member “maintains an automobile for the pleasure, use and convenience of his family and in pursuance of such purpose authorizes members of his family to use it for such purpose, he by so doing makes such pleasure uses his affair, and constitutes members of the family so operating the car his agents engaged in the prosecution of his affairs.” Id. at 179; see also Dibble v. Wolff, 135 Conn. 428 (1949).