Wisconsin Statutes
Wis. Stat. § 344.51 (2026)
Financial responsibility for domestic rented or leased vehicles
✓ current as of July 2026
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344.51(1g)(a)(a) “Lessor” means a person who, for compensation, leases a motor vehicle to a lessee to be operated by or with the consent of the lessee or who acquires a contract for the leasing of a motor vehicle from another person.
344.51(1g)(c)(c) “Rental company” means a person who, for compensation, rents a motor vehicle to a renter to be operated by or with the consent of the renter or who acquires a contract for the renting of a motor vehicle from another person.
344.51(1m)(1m) No lessor or rental company may for compensation rent or lease any motor vehicle unless there is filed with the department on a form prescribed by the department a certificate for a good and sufficient bond or policy of insurance issued by an insurer authorized to do an automobile liability insurance or surety business in this state. The certificate shall provide that the insurer which issued it will be liable for damages caused by the negligent operation of the motor vehicle in the amounts set forth in s. 344.01 (2) (d). No lessor or rental company complying with this subsection, and no lessor or rental company entering into or acquiring an interest in any contract for the rental or leasing of a motor vehicle for which any other lessor or rental company has complied with this subsection, is liable for damages caused by the negligent operation of the motor vehicle by another person.
344.51(2)(2) Any lessor or rental company failing to comply with this section is directly liable for damages caused by the negligence of the person operating such rented or leased vehicle, but such liability may not exceed the limits set forth in s. 344.01 (2) (d) with respect to the acceptable limits of liability when furnishing proof of financial responsibility.
344.51 HistoryHistory: 1971 c. 278; 1977 c. 29 s. 1654 (7) (a); 1979 c. 102; 1995 a. 329; 1997 a. 48.
344.51 AnnotationA lessor is not liable to the lessee’s insurer for monies that the insurer paid to a victim of the lessee’s negligence. American Family Mutual Insurance Co. v. Reciprocal Ins. Service Exchange Mgt. Co. 111 Wis. 2d 308, 330 N.W.2d 223 (Ct. App. 1983).
344.51 AnnotationWhen a lessee’s insurance was insufficient to cover all damages, the lessor’s errors and omissions policy was required to cover remaining damages. Germanotta v. National Indemnity Co. 119 Wis. 2d 293, 349 N.W.2d 733 (Ct. App. 1984).
344.51 AnnotationNo statute requires a self-insured entity under s. 344.16 to provide uninsured motorist coverage as part of the optional insurance it offers to its customers. Prophet v. Enterprise Rent-A-Car Company, Inc. 2000 WI App 171, 238 Wis. 2d 150, 617 N.W.2d 225, 99-0776.
344.51 AnnotationA car-rental company issued a certificate of self-insurance under s. 344.16 and subject to liability limits under s. 344.01 (2) (d) and this section was not a self-insurer for purposes of an underinsured motorist clause that excluded coverage for a vehicle owned or operated by a “self-insurer.” Bethke v. Auto-Owners Insurance Company, 2013 WI 16, 345 Wis. 2d 533, 825 N.W.2d 482, 10-3153.
Notes of Decisions
Cited in 16
cases, 1970–2013 · leading case: Bethke v. Auto-Owners Ins., 2013 WI 16 (Wis. 2013).
Bethke v. Auto-Owners Ins., 2013 WI 16 (Wis. 2013). “We conclude that as applied, the policy term "self-insurer" is ambiguous because it is unclear whether a reasonable insured would understand that a car rental company which is statutorily liable under Wis. Stat. § 344.51 is a "self-insurer" under the policy.”
Boatright v. Spiewak, 570 N.W.2d 897 (Wis. Ct. App. 1997). “The argument concerning § 344.51, Stats., employs the same reasoning the appellants apply to the § 344.”
Casper v. Am. Int'l South Ins., 2010 WI App 2 (Wis. Ct. App. 2009). “§§ 344.51 or 344.52. Ryder and ORIC further contend that, although the circuit court did not address the issue, presumably because the court found that the MCS-90 endorsement allowed the Caspers to collect a judgment from ORIC, the Wisconsin omnibus statute, WIS.”
Germanotta v. Nat'l Indem. Co., 349 N.W.2d 733 (Wis. Ct. App. 1984). “National and Peters moved for summary judgment contending that Peters’ duty and the statutory purpose of sec. 344.51, Stats., had been fulfilled by Lieungh’s American Family policy.”
Osman v. Phipps, 2002 WI App 170 (Wis. Ct. App. 2002). “1 In our 1999 decision, we mistakenly utilized the 1995-96 version of Wis. Stat. § 344.51 rather than the 1993-94 version, which, because it was in effect at the time of the rental agreement, applied to the facts of this case.”
Classified Ins. Co. v. Budget Rent-A-Car of Wisconsin, Inc., 521 N.W.2d 177 (Wis. Ct. App. 1994). “Although we agree that under the appropriate circumstances, §344.51, Stats., is designed to "assure response in damages," nonetheless, we disagree with Classified's contention that the statute applies in this case.”
Brown v. Tokio Marine & Nichido Fire Ins., 2012 WI App 45 (Wis. Ct. App. 2012). “Does Wis. Stat. § 344.51 (1m) Mandate Coverage by Nissan ? ¶ 17.”
Prophet v. Enter. Rent-a-car Co., Inc., 2000 WI App 171 (Wis. Ct. App. 2000). “A motor vehicle rental company operating in Wisconsin is subject to the requirements of Wis. Stat. § 344.51 , a section of Wisconsin's financial responsibility law for rented vehicles.”
Cortes v. Ryder Truck Rental, Inc., 581 N.E.2d 1 (Ill. App. Ct. 1991). “Cortes had amended their complaint to add count II, alleging Ryder’s liability for the full amount of damages under the Wisconsin financial responsibility statute ( Wis. Stat. §344.51 (1985).) The trial court denied Mr.”
Cates v. Creamer, 431 F.3d 456 (5th Cir. 2005). “47, § 8-102 (c); Wis. Stat. Ann. §§ 344.51 (2), 344.01(2)(d) (1999); McGrew v.”
Grabski v. Finn, 630 F. Supp. 1037 (E.D. Wis. 1986). “Grabski cites section 344.51(2) which is titled "Financial Responsibility for Domestic Rented Vehicles.”
Gann v. William Timblin Transit, Inc., 522 F. Supp. 2d 1021 (N.D. Ill. 2007). “Wis. Stat. Ann. 344.51 states: (lm) No lessor or rental company may for compensation rent or lease any motor vehicle unless there is filed with the department on a form prescribed by the department a certificate for a good and sufficient bond or policy of insurance issued by an…”
— Wis. Stat. § 344.51(1) — 7 cases
Boatright v. Spiewak, 570 N.W.2d 897 (Wis. Ct. App. 1997). “The argument concerning § 344.51, Stats., employs the same reasoning the appellants apply to the § 344.”
Germanotta v. Nat'l Indem. Co., 349 N.W.2d 733 (Wis. Ct. App. 1984). “National and Peters moved for summary judgment contending that Peters’ duty and the statutory purpose of sec. 344.51, Stats., had been fulfilled by Lieungh’s American Family policy.”
Osman v. Phipps, 2002 WI App 170 (Wis. Ct. App. 2002). “1 In our 1999 decision, we mistakenly utilized the 1995-96 version of Wis. Stat. § 344.51 rather than the 1993-94 version, which, because it was in effect at the time of the rental agreement, applied to the facts of this case.”
Brown v. Tokio Marine & Nichido Fire Ins., 2012 WI App 45 (Wis. Ct. App. 2012). “Does Wis. Stat. § 344.51 (1m) Mandate Coverage by Nissan ? ¶ 17.”
Prophet v. Enter. Rent-a-car Co., Inc., 2000 WI App 171 (Wis. Ct. App. 2000). “A motor vehicle rental company operating in Wisconsin is subject to the requirements of Wis. Stat. § 344.51 , a section of Wisconsin's financial responsibility law for rented vehicles.”
— Wis. Stat. § 344.51(1m) — 1 case
Bethke v. Auto-Owners Ins., 2013 WI 16 (Wis. 2013). “We conclude that as applied, the policy term "self-insurer" is ambiguous because it is unclear whether a reasonable insured would understand that a car rental company which is statutorily liable under Wis. Stat. § 344.51 is a "self-insurer" under the policy.”
— Wis. Stat. § 344.51(2) — 5 cases
Boatright v. Spiewak, 570 N.W.2d 897 (Wis. Ct. App. 1997). “The argument concerning § 344.51, Stats., employs the same reasoning the appellants apply to the § 344.”
Grabski v. Finn, 630 F. Supp. 1037 (E.D. Wis. 1986). “Grabski cites section 344.51(2) which is titled "Financial Responsibility for Domestic Rented Vehicles.”
Casper v. Am. Int'l South Ins., 2010 WI App 2 (Wis. Ct. App. 2009). “§§ 344.51 or 344.52. Ryder and ORIC further contend that, although the circuit court did not address the issue, presumably because the court found that the MCS-90 endorsement allowed the Caspers to collect a judgment from ORIC, the Wisconsin omnibus statute, WIS.”
Am. Fam. Mut. Ins. v. Reciprocal Ins. Serv. Exch. Mgmt., 330 N.W.2d 223 (Wis. Ct. App. 1983).
Am. Fam. Mut. Ins. v. Reciprocal Ins., 330 N.W.2d 223 (Wis. Ct. App. 1983).
— Wis. Stat. § 344.51(lm) — 2 cases
Bethke v. Auto-Owners Ins., 2013 WI 16 (Wis. 2013). “We conclude that as applied, the policy term "self-insurer" is ambiguous because it is unclear whether a reasonable insured would understand that a car rental company which is statutorily liable under Wis. Stat. § 344.51 is a "self-insurer" under the policy.”
Brown v. Tokio Marine & Nichido Fire Ins., 2012 WI App 45 (Wis. Ct. App. 2012). “Does Wis. Stat. § 344.51 (1m) Mandate Coverage by Nissan ? ¶ 17.”
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