Worley v. Weigels, Inc.
919 S.W.2d 589 (1996)
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Rule of Law:
Under Tennessee statute, a seller of alcoholic beverages is not civilly liable for injuries caused by an intoxicated person unless the seller sold the alcohol to a person they knew was a minor, and that specific minor who purchased the beverage caused the injury as a direct result of their own consumption of the alcohol sold.
Facts:
- A group of friends under 21 years of age, including Phillip Worley, Anthony Kaiser, and Scott Goosie, gathered at a residence.
- During the evening, Goosie, who was 20 years old, was sent to a store owned by Weigel's, Inc. to purchase beer.
- A clerk at Weigel's sold a substantial quantity of beer to Goosie without asking for or being shown any proof of age.
- Goosie did not consume any of the beer he purchased.
- Anthony Kaiser became intoxicated by drinking the beer that Goosie had purchased from Weigel's.
- While driving at a high rate of speed with Worley as a passenger, the intoxicated Kaiser lost control of his vehicle and crashed into a utility pole.
- Phillip Worley sustained serious and permanent personal injuries as a result of the crash.
Procedural Posture:
- Phillip Worley's parents sued Weigel's, Inc. in a Tennessee trial court.
- Weigel's, Inc. filed a motion for summary judgment, arguing it was not liable under state statutes.
- The trial court granted summary judgment in favor of Weigel's, Inc., holding that the statute only imposes liability if the purchaser's own consumption causes the injury.
- The plaintiffs (appellants) appealed to the Tennessee Court of Appeals.
- The Court of Appeals, an intermediate appellate court, reversed the trial court's grant of summary judgment.
- Weigel's, Inc. (appellant) appealed the reversal to the Supreme Court of Tennessee.
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Issue:
Does a seller of alcoholic beverages have civil liability under Tenn. Code Ann. § 57-10-102 for injuries caused by an intoxicated minor when the seller sold the alcohol to a different minor who did not consume it but provided it to the one who caused the injuries?
Opinions:
Majority - Reid, Justice
No. Under Tenn. Code Ann. § 57-10-102, a seller of alcoholic beverages is not liable for injuries caused by an intoxicated minor unless the minor who purchased the alcohol is the same person who consumed it and directly caused the injury. The court's reasoning is based on a strict interpretation of Tennessee statutes that replaced the common law foreseeability test. The general rule, established by Tenn. Code Ann. § 57-10-101, is that the 'consumption' of alcohol, not its 'furnishing,' is the proximate cause of injuries inflicted by an intoxicated person. While § 57-10-102 creates a narrow exception for sales to a known minor, it explicitly requires that 'such person'—meaning the purchaser—'caused the personal injury or death as the direct result of the consumption of the alcoholic beverage or beer so sold.' In this case, the purchaser (Goosie) did not consume the beer or cause the injury; the injury was caused by Kaiser, who did not purchase the beer. Therefore, the statutory exception for seller liability does not apply. The court found the statutory language to be a 'model of clarity' and noted that legislative history confirmed the intent to insulate sellers from liability except in these very specific circumstances.
Analysis:
This decision significantly curtails vendor liability for selling alcohol to minors in Tennessee, replacing the common law's flexible 'foreseeability' test with a rigid, statutory bright-line rule. By insulating sellers from liability unless the purchaser is the one who consumes the alcohol and causes the harm, the ruling effectively eliminates liability in common 'chain of distribution' scenarios where one minor buys for a group. This interpretation heavily favors commercial vendors and places a higher burden on plaintiffs, who must now prove a direct, unbroken line from the specific sale to the specific purchaser's consumption and subsequent injurious act. The decision illustrates a judicial deference to legislative policy choices, even when those choices lead to outcomes that might seem unjust under traditional tort principles.
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