Reynolds v. Hicks (Washington, 1998)

Procedural History: Plaintiffs appeal a trial court decision dismissing their personal injury action on summary judgment against defendants.

Facts: Jamie and Anna Hicks were married on September 10, 1988 at St. Bernadette Church in Seattle. Three hundred attended the wedding, including Jamie Hick’s under-age nephew, Steven Hicks. The wedding was followed by a dinner reception where wine and champagne were served and drinks were available at a hosted bar. At about midnight, Steven Hicks left in his sister’s car and at 1am, he was involved in an automobile accident with plaintiff Reynolds.

Issue: Should a social host have a duty to third persons injured by an intoxicated minor?

Rules: RCW 66.44.270 makes it unlawful for any person [except a parent] to:

“give or otherwise supply liquor to any person under the age of 21 or permit any person under that age to consume liquor on his or her premises or on any premises under his or her control.”

Hansen v. Friend

The court recognized that a minor who is injured as a result of alcohol intoxication has a cause of action against the social host who supplied the alcohol.

Application: Although a social host has a duty to the minor if the social host furnishes alcohol to the minor, a social host is not capable of handling the responsibilities of monitoring their guests’ alcohol consumption in the same way as commercial or quasi-commercial counterparts. Because of this:

Application: Court affirmed the trial court’s dismissal finding that social hosts owe no duty to third persons injured by an intoxicated minor. Although commercial proprietors have a duty to third persons injured by an intoxicated person whom has been furnished alcohol by the proprietor, social hosts do not owe the same duty to third parties injured by intoxicated minors.

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