Nelson v. Artley

Under Vehicle Code, rental car company's financial responsibility is limited to the same minimum coverage provisions applicable to rental car companies electing to meet their financial responsibility obligations through the purchase of an insurance policy. Rental car companies electing to meet their proof of financial responsibility obligations under Section 9-101 by self-insuring under Section 9-102(3) are subject to the same minimum coverage provisions applicable to rental car companies electing to meet their financial responsibility obligations through the purchase of insurance policies under Section 9-102(2). "Proof of financial responsibility", as defined and used in Vehicle Code, is not proof of ability to fully satisfy judgments, but is proof of ability to provide some base level of financial coverage where otherwise there would be none. (GARMAN, FREEMAN, THOMAS, KILBRIDE, BURKE, and THEIS, concurring.)