Brian Martin v. Matthew J. Marciano et al.
871 A.2d 911 (2005)
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Rule of Law:
A social host who provides alcoholic beverages to underage guests, or has actual knowledge of underage alcohol consumption on their property, owes a duty to exercise reasonable care to protect guests from reasonably foreseeable physical assault by third parties.
Facts:
- Lee Martin hosted a high school graduation party for her daughter, Jen Martin, at her home.
- The party had approximately seventy guests, most of whom were underage, and invitations were spread by word-of-mouth.
- Brian Martin, a guest, alleged that two kegs of beer were available and that he and other underage guests consumed alcohol at the party.
- A fight broke out between another guest, Matthew Marciano, and some of Brian Martin's friends.
- Brian Martin told Marciano to leave to de-escalate the situation.
- Marciano left the party, called his friend Chijoke Okere, and supplied Okere with a baseball bat to return as 'reinforcements'.
- Approximately 30 to 60 minutes later, Marciano and Okere returned to the party.
- Okere, wielding the bat, asked who had fought with Marciano and then struck Brian Martin on the head, causing significant brain damage.
Procedural Posture:
- Brian Martin (plaintiff) filed a lawsuit against Lee Martin (defendant), Chijoke Okere, and Matthew Marciano in the Superior Court (trial court).
- Lee Martin filed a motion for summary judgment, arguing she owed no legal duty to protect the plaintiff.
- The trial court motion justice granted summary judgment in favor of Lee Martin, concluding that the attack was unforeseeable and therefore no duty existed.
- Brian Martin (appellant) timely appealed the grant of summary judgment to the state's highest court.
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Issue:
Does a social host who provides or knowingly allows the consumption of alcohol by underage guests on their property owe a duty of reasonable care to protect those guests from foreseeable physical assault by a third party?
Opinions:
Majority - Williams, Chief Justice
Yes. A social host who makes alcohol illegally available to underage guests owes a duty to exercise reasonable care to protect them from foreseeable harm. Although a landowner generally has no duty to protect others from the criminal acts of third parties, an exception exists where there is a special relationship. The court extends the special relationship recognized between commercial vendors of alcohol and their patrons to a social host who knowingly provides alcohol to minors on their property. This duty is supported by strong public policy against underage drinking, as evidenced by numerous state statutes. The criminal assault in this case was not an unforeseeable superseding cause as a matter of law, because it is common knowledge that alcohol consumption, especially by minors, can lead to violence. Therefore, whether the host breached her duty and whether the assault was a foreseeable consequence of her negligence are questions of fact for a jury to decide.
Analysis:
This decision significantly expands social host liability by extending a duty of care, traditionally applied to commercial establishments like bars, to private individuals who host parties with underage drinking. It establishes that a host cannot 'turn a blind eye' to illegal alcohol consumption and may be held liable for resulting violence, even if perpetrated by a third party. The ruling emphasizes that a third party's criminal act does not automatically sever the chain of causation if the act was a foreseeable result of the host's negligence in creating a dangerous environment. This case serves as a strong precedent for holding adults accountable for the foreseeable consequences of facilitating underage drinking.
