Pauline Eddy v. Bricktown Hospitality, LLC

Sharon Eddy, age 61, was staying at the Bricktown SpringHill Suites in Oklahoma City with her mother, Pauline Eddy (plaintiff). Around 7:30 p.m. Sharon visited the hotel bar, where bartenders Cody Wisley and Lauren Jackson served her a vodka cocktail, four high-alcohol beers, and a shot of whiskey. Sharon occasionally left to smoke or use the restroom. After her last cigarette, Sharon spoke louder, but she did not have bloodshot eyes or slurred speech. The bartenders nonetheless cut her off; Sharon agreed and consumed water instead of additional alcohol. Around 10:13 p.m., Sharon paid her tab, but she fell as she stood from her barstool. Wisley and Jackson helped her up but did not believe she needed emergency medical attention. Wisley retrieved a rolling office chair, and two female hotel employees rolled Sharon to her room, unaware of her earlier fall or bar cutoff. Sharon was coherent and happy and required minimal assistance once in her room. Pauline, who spoke with Sharon upon her return, noticed no signs of significant intoxication or injury. Around 3:00 a.m., Sharon was found deceased. The medical examiner determined Sharon’s cause of death was acute ethanol toxicity, with a blood alcohol concentration of 0.30 g/dL. Pauline sued the hotel’s owner, Bricktown Hospitality, LLC (Bricktown) (defendant), alleging that Bricktown was negligent in two respects: first, by voluntarily assuming responsibility for Sharon and failing to exercise reasonable care in doing so, and second, by failing to meet the high degree of care owed by an innkeeper to its guests. Bricktown moved for summary judgment.