Lindsey v. Miami Development Corp.
1985 Tenn. LEXIS 511, 689 S.W.2d 856 (1985)
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Rule of Law:
A social host has an affirmative duty to exercise reasonable care to render aid to a guest who is seriously injured. Alternatively, a duty to render aid arises when a person voluntarily assumes control of an emergency situation involving an injured individual.
Facts:
- Troy Lee Castile hosted a political fundraiser in a building where he also maintained living quarters.
- Vickie Lindsey, a guest at the fundraiser, was observed to have a blood alcohol content of 0.23%.
- Lindsey sat on the edge of a balcony overlooking a stone foyer and, after a brief exchange with Castile, jumped or fell, striking her head on the stone steps below.
- After Lindsey was rendered unconscious, Castile allegedly instructed other guests to 'wait a while before you call an ambulance.'
- An ambulance was called at 2:19 a.m., approximately five minutes after another guest had first called a hospital for advice.
- Lindsey arrived at the hospital unconscious with dilated pupils and no cardiac activity.
- Dr. Parsons pronounced her dead at 3:00 a.m. from what he determined was a basilar skull fracture.
- No autopsy was performed, and the treating physician testified that any opinion on whether immediate medical care would have changed the outcome would be speculative.
Procedural Posture:
- The plaintiff, Lindsey's father, filed a wrongful death action against Troy Lee Castile and Miami Development Corporation in a state trial court.
- The trial court granted summary judgment in favor of both defendants on all claims.
- The plaintiff appealed the summary judgment to the Tennessee Court of Appeals.
- The Court of Appeals affirmed summary judgment on the premises liability claim but reversed summary judgment for Castile on the failure-to-render-aid claim, remanding it for trial.
- Castile, as the appellant, appealed the reversal of summary judgment on the failure-to-render-aid claim to the Supreme Court of Tennessee.
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Issue:
Does a social host owe a legal duty to exercise reasonable care to render aid to a guest who becomes seriously injured on the host's premises?
Opinions:
Majority - Drowota, Justice
Yes. A social host owes a duty to render reasonable aid to an injured guest because the host-guest relationship is a 'special relationship' that creates an exception to the general common law rule of no duty to rescue. The court reasoned that while the common law is slow to impose a duty to aid a person in peril, exceptions exist where a special relationship, such as that between a carrier and passenger or an innkeeper and guest, justifies it. The court extends this exception to the social host-guest relationship, creating a duty to exercise reasonable care when a host knows or should know a guest is seriously injured. Alternatively, the court found that a duty arose when Castile voluntarily assumed control of the situation by allegedly telling others to delay calling an ambulance; one who takes charge of an emergency is liable for failure to use reasonable care. However, the court found the plaintiff had not yet presented sufficient evidence of proximate cause, as the only medical testimony was speculative about whether a delay in aid caused the death, and remanded this issue to the trial court.
Analysis:
This case is significant for formally recognizing the social host-guest relationship as a 'special relationship' in Tennessee law, thereby creating an affirmative duty for hosts to render reasonable aid to injured guests. This decision moves away from the traditional common law rule that one has no duty to aid another in peril. It also reinforces the established principle of 'assumed duty,' where one who voluntarily takes control of a situation must act with reasonable care. The court's strict treatment of the proximate cause element, requiring non-speculative expert testimony, underscores the difficulty plaintiffs face in proving that a failure to render aid actually caused or worsened the harm.
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