| Venue: | WA SC |
| Facts: | The Hickses get married, and it's a big party, with 300 people there. A young relative, Steven, is served alcohol. He drives off with his sister, and they smash into Reynolds. Reynolds and his family settle with Steven and sister, but allege that the newlyweds were negligent in serving Steven, knowing that he was underage. |
| Posture: | Summary judgment at trial for defendants, dismissing the claim. |
| Issue: | Do social hosts who furnish alcohol to a minor owe a duty of care to third parties injured by the drunken kid? |
| Holding: | No. The dismissal is affirmed. |
| Rule: | The court declines to extend social host liability to third parties injured by intoxicated minors. |
| Reasoning: | Social hosts aren't capable of the same level of monitoring: the commercial vendor is motivated by profit, and better organized. Making social hosts liable would affect a lot of people: most adults, actually, and on a regular basis. Do we want to impose a duty for anyone who has a social gathering to hire a bartender, or card family members, or search youngsters to make sure they didn't BYOB, or have breathalyzers? Probably not. |
| Dicta: | Both social hosts and commercial vendors are committing a criminal act when they serve a minor: they already have a responsibility to avoid criminal conduct. This would impose no new duties on them, despite what the court says. |