Wallace v. Wilson
575 N.E.2d 1134, 411 Mass. 8 (1991)
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Rule of Law:
A social host parent does not owe a duty of reasonable care to third parties injured by minor guests who consumed alcohol at a party held at the parent's home, even if the parent knew or should have known alcohol would be available and was present during the party, provided the parent did not supply the alcohol.
Facts:
- Audrey Wilson reluctantly agreed to allow her seventeen-year-old daughter to hold a party at her home and chose to remain there as a chaperone to ensure everything was under control and no liquor was brought in.
- Teenage guests arrived at the party carrying six-packs of beer without concealing them, and everyone at the party was observed drinking beer and other liquor.
- Wilson remained mostly on the upper level of the split-level house but went downstairs twice; guests frequently went in and out through the garage without entering the upper part of the house.
- Around 11 p.m., Wilson overheard conversations indicating that one of the boys had upset a girl, Corin Acherson, and that Acherson's boyfriend planned to come to the house to beat up the boy.
- Around 11:30 p.m., Wilson told her daughter to end the party and send her guests home.
- The plaintiffs, John Tessier and James Wallace, along with two other boys, arrived uninvited at the Wilson home, unaware of the earlier incident.
- The Belmont boys, hearing a confrontation at the door between Wilson and the new arrivals, went outside through the garage.
- The Belmont boys violently attacked Tessier and Wallace with a pitchfork, sticks, and poles, inflicting serious injuries.
Procedural Posture:
- The plaintiffs, John Tessier and James Wallace, alleged assault and battery against Audrey Wilson and other defendants in separate cases.
- The cases were consolidated for the purpose of hearing and disposition of motions.
- Audrey Wilson filed a motion for summary judgment in both cases.
- The motion judge granted summary judgment to the Wilsons in both cases.
- The plaintiffs appealed the judgments in favor of Audrey Wilson.
- The Supreme Judicial Court of Massachusetts transferred the cases on its own initiative.
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Issue:
Does a social host parent owe a duty of reasonable care to uninvited third parties who are assaulted by minor guests who consumed alcohol at a party held at the parent's home, where the parent did not supply the alcohol but was aware of its consumption and present during the party?
Opinions:
Majority - O’Connor, J.
No, a social host parent does not owe a duty of reasonable care to uninvited third parties who are assaulted by minor guests who consumed alcohol at a party held at the parent's home, even where the parent did not supply the alcohol but was aware of its consumption and present during the party. The court affirmed the rule established in `Langemann v. Davis`, which held that a parent who neither provides nor makes alcoholic beverages available to minor guests at a party generally owes no duty to third-party victims, even if the parent knew or should have known alcohol would be available. The court found no principled distinction that would warrant a different outcome in this case; it stated that it should make no difference whether the plaintiffs were victims of an automobile accident or an assault and battery, nor whether the parent was at home supervising the party or away. The determination of whether a duty exists is a question of law, to be guided by existing social values, customs, and appropriate social policy. The court concluded that sound social policy would not be advanced by a rule that would place a parent who absents himself or herself during a party in a better position than a parent who remains on the scene to supervise.
Analysis:
This case reinforces the Supreme Judicial Court of Massachusetts's restrictive approach to social host liability, particularly for parents whose minor guests consume alcohol that the parents did not provide. It clarifies that the mere presence of the parent and their awareness of alcohol consumption at a party, without directly supplying the alcohol, does not create a duty of care to protect third parties from injuries caused by intoxicated guests. By equating assault and battery with automobile accidents and deeming a parent's presence irrelevant in establishing duty, the court significantly limits potential negligence claims against social hosts, emphasizing that the focus remains on the provision of alcohol rather than general supervision.
