Hoyt v. Gutterz Bowl & Lounge L.L.C.
Iowa Supreme Court
829 N.W. 2d 772 (2013)
- Written by Eric Miller, JD
Facts
Curtis Hoyt (plaintiff) went to Gutterz Bowl & Lounge (Gutterz) (defendant), a bowling alley and bar, to have drinks with a friend. Also present at Gutterz was Curtis Knapp. Hoyt and Knapp knew one another, but their relationship had taken a tense and unfriendly turn. Hoyt formed the impression that Knapp was scowling at him. Hoyt verbally confronted Knapp, who remained silent. The waitress serving Hoyt grew fearful of an altercation and discontinued service. Gutterz’s owner, also sensing danger, asked Hoyt to leave. Hoyt exited, followed by Knapp, who struck Hoyt in the back of the head in the parking lot. Hoyt brought an action against Gutterz, alleging that Gutterz was liable for his injuries. The district court granted summary judgment in favor of Gutterz, finding that Gutterz owed no duty of care to Hoyt. The court of appeals reversed, finding that the bar-patron relationship raised foreseeability questions that made summary judgment inappropriate. The case then went to the Iowa Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Hecht, J.)
Dissent (Waterman, J.)
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