Rong Yao Zhou v. Jennifer Mall Restaurant, Inc.

534 A.2d 1268 (1987)

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Rong Yao Zhou v. Jennifer Mall Restaurant, Inc.

District of Columbia Court of Appeals
534 A.2d 1268 (1987)

Facts

Rong Yao Zhou and Xiu Juan We (plaintiffs) were injured when they were hit by a drunk driver. The driver had been drinking at a restaurant owned by Jennifer Mall Restaurant, Inc. (the restaurant) (defendant), where in violation of District of Columbia law he had been served alcohol after becoming visibly intoxicated. Zhou and We were District of Columbia residents, and the restaurant was located in the District of Columbia. However, the accident occurred in Maryland, just over the District of Columbia border. Under Maryland law, bar owners that serve visibly intoxicated customers are subject to criminal sanctions but are not subject to civil liability to victims injured by the intoxicated customers. Under District of Columbia law, victims may recover in civil actions against bar owners that serve visibly intoxicated customers who ultimately injure the victims. The trial court granted restaurant’s motion for judgment on the pleadings.

Rule of Law

Issue

Holding and Reasoning (Newman, J.)

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