Reynolds' assignment placed her under the supervision of Doris Hicks. 1800 (published) Artist/maker. Kelly implicitly recognized the Washington State Liquor Act protects third parties from injury. The wedding was followed by a dinner reception where wine and champagne were served. The majority quotes Burkhart: "Because social hosts are generally unaccustomed to the pressures involved in taking responsibility for the intoxication of their guests, we cannot predict how well social hosts would respond when the scope of their duties would be so ill defined." RCW 66.20.210. The Hansen court further held social hosts liable in negligence when the minor sustains injury proximately caused by a breach of this duty. First, in 1989, Reynolds applied to become a middle school assistant principal.1 Reynolds interviewed for the position and was placed into a pool out of which principalship vacancies would be filled. See CP at 18 D-F. Also the children of Mr. Reynolds sought damages for their loss of companionship and future financial and emotional support of their father. . [6] Consequently, Defendants are not entitled to reasonable attorneys fees pursuant to RCW 4.84.250. Although Hansen did not create a cause of action for third parties, this court recognized such an action was allowed, based on the statute criminalizing furnishing alcohol to a minor. This means you can view content but cannot create content. Hansen, 118 Wash.2d at 479, 824 P.2d 483. Helsell, Fetterman, Martin, Todd & Hokanson, Patricia Anderson, Lish Whitson, Seattle, for Respondent. See RCW 66.44.270(4), (5). See CP at 18 D-F. Jodee Reynolds sought damages for personal injuries she sustained as a result of the accident and for loss of assistance and affection of her husband. A third party who is injured by an intoxicated minor may not sue the social hosts who provided the alcohol to the minor under the statute making such provision of alcohol to minors illegal. LSAT Logic Games (June 2007 Practice Exam), LSAT Logical Reasoning I (June 2007 Practice Exam), LSAT Logical Reasoning II (June 2007 Practice Exam), Randi W. v. Muroc Joint Unified School District, A.W. The Restatement provides: "The court may adopt as the standard of conduct of a reasonable [person] the requirements of a legislature enactment ... whose purpose is found to be exclusively or in part. See Young, 99 Wash.2d at 660, 663 P.2d 834. (Johnson, J.) See Mutual of Enumclaw Ins. Majority at 765. Plaintiff Timmy Reynolds, his wife JoDee, and children Matthew, Andrew, and Weslee originally sued Steven Hicks, his sister Dianne, and Does I through V 1 in October, 1990. The majority draws an insupportable distinction between social hosts and commercial vendors by ignoring that both are committing criminal acts when they furnish alcohol to a minor. Thank you. See id. 105 likes. To establish foreseeability, "the harm sustained must be reasonably perceived as being with the general field of danger covered by the specific duty owed by the defendant." 486, 492, 607 P.2d 890 (1980). See Hostetler v. Ward, 41 Wash.App. The source of the alcohol should not dictate whether a remedy is available. Previously cities included Holly Springs NC and Knightdale NC. 636, 640, 705 P.2d 806 (1985); Northside Auto Serv., Inc. v. Consumers United Ins. Majority at 764. Whether a party owes a duty to the plaintiff is a question of law. Hansen, 118 Wash.2d at 482, 824 P.2d 483. 7. See Klein v. City of Seattle, 41 Wash.App. CP at 532. Written and curated by real attorneys at Quimbee. On the contrary, the scope of a duty in this situation would not be ill defined. 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