Reynolds v. Hicks
Washington Supreme Court
951 P.2d 761 (1998)
- Written by Angela Patrick, JD
Facts
Jamie and Anna Hicks (the Hickses) (defendants) were married and hosted a wedding reception. Three hundred people attended the reception, including Jamie’s 17-year-old nephew Steven Hicks (defendant). During the reception, drinks were available at a hosted bar. At some point, Steven consumed alcohol. Jamie, Anna, and other relatives, including Steven’s sister and aunt, did not see Steven drinking, nor did Steven appear to be drunk. An hour after Steven drove away from the reception, he was involved in a car accident with Timothy Reynolds (plaintiff). At the time, both Reynolds and Steven had blood alcohol levels above the legal limit. Reynolds suffered serious injuries. Reynolds and his family sued the Hickses for negligence, based on social-host liability. Reynolds claimed that the Hickses were negligent in serving alcohol to Steven and allowing him to become intoxicated. The trial court dismissed the negligence claim, ruling that social hosts did not owe a duty of care to third parties who were injured by intoxicated minors. Reynolds appealed the decision to the court of appeals, which certified the case to the Washington Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Madsen, J.)
Concurrence (Durham, C.J.)
Dissent (Johnson, J.)
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