On October 14, 2025, the United States Supreme Court denied certiorari in Malco Enterprises of Nevada, Inc. v. Woldeyohannes, allowing a pivotal decision from the Nevada Supreme Court to stand. This outcome preserved Nevada’s authority to enforce liability insurance standards for rental car companies and affirmed protections for victims of rental vehicle accidents. Hilton Parker LLC, representing respondent Alelign Woldeyohannes, successfully preserved this historic ruling.

What the Case Was About

The case arose from a 2018 traffic collision in Las Vegas in which Alelign Woldeyohannes was rear-ended by a rental vehicle operated by a driver who defaulted in court. Woldeyohannes obtained a judgment against the driver and then sought recovery from the rental car company, Malco Enterprises, under Nevada Revised Statutes (NRS) § 482.305. The statute imposes joint and several liability on rental companies that fail to ensure their vehicles are covered by Nevada’s minimum liability insurance requirements.

The Nevada Supreme Court held that Malco had failed to provide such coverage and upheld a judgment of $37,886.82 against the company. Malco petitioned the U.S. Supreme Court, claiming that the Nevada statute was preempted by the federal Graves Amendment, which generally bars states from holding rental car companies vicariously liable for drivers’ conduct.

Why It Mattered

The case presented a significant preemption issue: whether Nevada’s insurance-enforcement statute was saved by the Graves Amendment’s express exemption for state laws imposing liability for failure to meet insurance requirements (49 U.S.C. § 30106(b)(2)). Had the Court taken the case and ruled in Malco’s favor, it might have invalidated not only Nevada’s statute but also similar laws in other jurisdictions.

Strategic Framing: A Decisive Move

Our response brief strategically reframed the question presented, steering it away from the abstract contours of federal preemption doctrine and toward the settled state law determination that Malco had violated Nevada’s insurance laws. The reframed question was:

“Once a court finds that a rental car company has failed to meet state liability insurance requirements with respect to a vehicle involved in a collision, does the Graves Amendment prohibit the court from imposing joint and several liability on the rental car company based on that failure?”

By anchoring the issue in Nevada’s own statutory scheme and judicial interpretation, Hilton Parker LLC effectively invited the U.S. Supreme Court to avoid second-guessing a state court’s reading of its own laws—a move that aligned with principles of federalism and judicial restraint.

A Strong Textual Defense of State Authority

Hilton Parker also advanced a straightforward, textualist reading of the Graves Amendment. The brief demonstrated that NRS § 482.305 is not a backdoor form of vicarious liability but a lawful mechanism to enforce compliance with minimum insurance requirements. The firm argued that the case fit squarely within the Graves Amendment’s savings clause, contrasting Nevada’s approach with other states’ laws that courts have struck down for attempting to bypass federal limits through indirect liability schemes.

The Supreme Court Declines Review

The Supreme Court’s denial of certiorari preserved the Nevada ruling and confirmed that states may, within the scope allowed by federal law, require rental car companies to provide minimum liability insurance—and hold them accountable when they don’t. The outcome reinforces the principle that well-crafted state insurance laws can coexist with federal tort reforms.

Why This Case Is a Landmark

This case is a model of how appellate strategy can shape outcomes even without a merits ruling. By focusing the Court’s attention on a narrow, state-grounded issue, Hilton Parker LLC helped avoid a potentially sweeping federal decision. The case stands as a high-impact affirmation of state authority to enforce consumer protections in the rental car industry—especially important in states like Nevada with large volumes of tourist drivers. Other states that wish to impose joint and several liability on rental car companies may now safely copy Nevada’s statutory scheme, allowing for greater accountability when rental car companies fail to insure their fleets.

Conclusion: The Art of the Certiorari Response

Malco v. Woldeyohannes illustrates a core lesson for appellate advocates: success often depends less on answering the question than on defining it. Hilton Parker LLC’s reframing strategy empowered the Supreme Court to deny review immediately upon review at conference, preserving a strong precedent and a vital state law.

For practitioners nationwide, the case is a reminder of how skilled briefing and disciplined issue framing can win the day—not by pushing for a fight, but by showing the court why it doesn’t need one.