Young v. Players Lake Charles, L.L.C.
United States District Court for the Southern District of Texas
47 F. Supp. 2d 832 (1999)
- Written by Brett Stavin, JD
Facts
On July 28, 1997, Angelina Rios, Katherine Young, Joshua Young, and Seth Young (collectively, Young) (plaintiffs), who were residents of Texas, were traveling westbound on an interstate highway in Louisiana when they collided head-on with a vehicle driven by Chris Dewayne West (defendant), who was traveling eastbound and drifted over the median into oncoming traffic. Angelina Rios, Katherine Young, and Seth Young died instantly or en route to the hospital. Joshua Young and West both survived but were each severely injured. Subsequent tests indicated that West was intoxicated at the time of the accident. West had been drinking for several hours while aboard the PLAYERS III, a Louisiana riverboat casino owned by Players Lake Charles, L.L.C. (Players Lake) (defendant). West received multiple complimentary drinks while gambling aboard the PLAYERS III. Young brought suit against Players Lake in federal district court, claiming that Players Lake negligently served alcohol to West when it knew or should have known that he was intoxicated and posed a danger to himself and others. Players Lake moved for summary judgment, arguing that the case was governed by the substantive negligence law of Louisiana, which shielded providers of alcohol from dram-shop liability. In response, Young argued that general maritime law provided the substantive law governing dram-shop liability, or in the alternative, that Texas law applied. Neither party disputed that admiralty jurisdiction was appropriate, and the court found that admiralty jurisdiction was indeed proper because the alleged tort occurred on navigable water and the issues in the case raised the potential for a disruptive impact on maritime commerce.
Rule of Law
Issue
Holding and Reasoning (Kent, J.)
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