Langemann v. Davis
1986 Mass. LEXIS 1441, 398 Mass. 166, 495 N.E.2d 847 (1986)
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Rule of Law:
A social host, particularly a parent, is not liable for injuries caused by the negligence of a minor guest who consumed alcohol furnished by another guest on the host's premises, when the host neither provided nor made available the alcoholic beverages, even if the host knew or reasonably should have known that alcohol would be available.
Facts:
- On January 8, 1983, the plaintiff was injured in a motor vehicle accident caused by Darren R. Hathaway's negligence.
- Hathaway, an underage high school student, had been drinking beer at a party given by defendant Davis's daughter shortly before the accident.
- Davis had permitted her daughter to host the party, but Davis was not home and had not provided any alcoholic beverages, nor were there any on the premises when she left prior to the party.
- Hathaway obtained the beer he consumed from another guest at the party.
- Hathaway's girlfriend believed he did not seem drunk when they left the party, and there was no other record evidence indicating his degree of intoxication either at the Davis home or at the time of the accident.
Procedural Posture:
- The plaintiff sued Davis in a trial court (court of first instance).
- Davis filed a motion for summary judgment, seeking a judgment in her favor without a full trial.
- The trial court allowed Davis's motion for summary judgment.
- The plaintiff appealed the allowance of Davis's motion for summary judgment to the Supreme Judicial Court of Massachusetts (the highest court, appellant: plaintiff, appellee: Davis).
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Issue:
Does a parent, as a social host, owe a duty of care to travelers on highways to supervise a party given by her minor child when the parent neither provides nor makes available alcoholic beverages, even if the parent knew or reasonably should have known that alcoholic beverages would be available to minor guests furnished by another guest?
Opinions:
Majority - Wilkins, J.
No, a parent, as a social host, does not owe such a duty of care. The court held that Davis's conduct did not create a risk of injury for which common law should provide a remedy because she did not serve or make available any alcoholic beverage to Hathaway. She merely provided the premises where Hathaway drank beer furnished by another guest. The court distinguished this situation from cases involving commercial vendors who sell to minors (where liability depends on the sale to a known minor, not intoxication) and from social hosts who provide alcohol to obviously intoxicated adult guests. The court explicitly rejected the argument that a parent who neither provides nor makes available alcoholic beverages owes a duty to supervise a party given by her minor child, even if she knew or should have known alcohol would be available.
Analysis:
This case significantly limits the scope of social host liability in Massachusetts, particularly concerning minors. It establishes that merely providing the premises for a party where minors consume alcohol, without actively providing or making the alcohol available, is insufficient to trigger liability. The decision differentiates social hosts from commercial vendors, who face stricter liability for sales to minors, and from social hosts who directly serve visibly intoxicated adults. This ruling reinforces the requirement of active involvement in the provision of alcohol as a prerequisite for imposing a duty of care on social hosts, thereby reducing the potential liability for parents under similar circumstances.
