By Harry M. Byrne and Ryan F. Monahan
On April 23, 2026, the New York Court of Appeals held in Second Child v. Edge Auto, Inc. that the federal Graves Amendment preempts New York’s minimum insurance statute to the extent it requires automotive rental companies to provide primary liability insurance coverage to renters up to the statutory minimum liability limits. The decision is a major victory for the rental industry and reinforces the broad protections Congress intended to provide the industry when it enacted the Graves Amendment.