KY DRAM SHOP MEMO II

Similar documents
Jeffrey V. Hill Bodyfelt Mount LLP 707 Southwest Washington St. Suite 1100 Portland, Oregon (503)

Title 28-A: LIQUORS. Chapter 100: MAINE LIQUOR LIABILITY ACT. Table of Contents Part 8. LIQUOR LIABILITY...

IN THE SUPREME COURT OF TEXAS

Alcohol Beverage Liability: Legal Update and Best Practices

TABLE OF CONTENTS 2.1 GENERAL RIGHT OF ACTION UNDER C.R.S LIMITED RIGHT OF ACTION UNDER C.R.S

No. 09SC1011, Build It and They Will Drink, Inc., d/b/a Eden Nightclub, and Rodney Owen Beers v. Michael Alan Strauch: Dram-Shop Liability.

APPORTIONMENT OF FAULT TO A NON-PARTY POINTING FINGERS TO VICTORY

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON November 18, 2015 Session

Alcohol Beverage Liability:

COURT OF APPEALS EIGHTH DISTRICT OF TEXAS EL PASO, TEXAS

MAINE STATE LEGISLATURE

NOTICE OF MOTION OF THE NEW JERSEY LAWSUIT REFORM ALLIANCE TO APPEAR AS AMICUS CURIAE

Lessor's Liability Under Dram Shop Act

STATE OF MICHIGAN COURT OF APPEALS

Commonwealth of Kentucky Court of Appeals

The section Causation: Actual Cause and Proximate Cause from Business Law and the Legal Environment was adapted by The Saylor Foundation under a

IN THE SECOND JUDICIAL DISTRICT COURT OF THE STATE OF NEVADA IN AND FOR THE COUNTY OF WASHOE * * * *

In the Court of Appeals of Georgia

STATE OF MICHIGAN COURT OF APPEALS

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

IN THE SUPREME COURT OF TEXAS

Commonwealth Of Kentucky Court of Appeals

The Contributory Negligence Act

HOUSE OF REPRESENTATIVES COMMITTEE ON JUDICIAL OVERSIGHT ANALYSIS

Social Host Liability in Missouri

STRICT LIABILITY. (1) involves serious potential harm to persons or property,

COURT OF APPEALS OF OHIO, EIGHTH DISTRICT

Maryland tort lawyers may need to re-think their understanding of

Strict Liability within the Federal Tort Claims Act: Does It Belong

Commonwealth of Kentucky Court of Appeals

Gun Laws Under The Influence. nonsense. The session of the California legislature just ended has once again

2011 PA Super 236. Appellant No. 5 EDA 2011

IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE April 15, 2011 Session

ELEMENTS OF LIABILITY AND RISK

Torts Common Law Dramshop Liability

Professor DeWolf Summer 2014 Torts August 18, 2014 SAMPLE ANSWER TO FINAL EXAM MULTIPLE CHOICE

JAMESTOWN S KLALLAM TRIBE TRIBAL CODE TITLE 24 TRIBAL LIQUOR CONTROL

IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE February 18, 2009 Session

CONTRIBUTORY NEGLIGENCE ACT

Commonwealth of Kentucky Court of Appeals

Civil Liability Amendment (Personal Responsibility) Act 2002 No 92

STATE OF MICHIGAN COURT OF APPEALS

Tort Law - New Mexico Examines the Doctrine of Comparative Fault in the Context of Premises Liability: Reichert v. Atler

M E M O R A N D U M. Executive Summary

Fall 1997 December 20, 1997 SAMPLE ANSWER TO MID-TERM EXAM QUESTION 1

ILLINOIS LAW MANUAL CHAPTER I CIVIL PROCEDURE. On June 11, 2003, Section was amended. The change specifically prohibits

VIOLET SEABOLT OPINION BY v. Record No JUSTICE WILLIAM C. MIMS April 20, 2012 COUNTY OF ALBEMARLE

IN THE SUPREME COURT OF THE STATE OF DELAWARE

WORKPLACE SAFETY AND INSURANCE APPEALS TRIBUNAL DECISION NO. 1086/15

7.32 COMPARATIVE NEGLIGENCE: INTERROGATORIES (Approved before 1985) NOTE TO JUDGE

MBE WORKSHOP: TORTS PROFESSOR LISA MCELROY DREXEL UNIVERSITY SCHOOL OF LAW

Restatement (Second) of Torts 496A (1965) Assumption of Risk

Government of the District of Columbia OFFICE OF THE CORPORATION COUNSEL JUDICIARY SQUARE 441FOURTH ST., N.W. WASHINGTON, D.C.

Summary of Contents. PART I. INTRODUCTION Chapter 1. An Introduction to the Restatement of Torts... 2

Chapter 6 Torts Byron Lilly De Anza College Byron Lilly De Anza College

AKRoN LAW REVIEW TORT LIABILITY. Liability of Liquor Vendors for Injuries to Intoxicated Persons

v. Record No OPINION BY JUSTICE BARBARA MILANO KEENAN March 3, 2000 MATT MARY MORAN, INC., ET AL.

Number 41 of 1961 CIVIL LIABILITY ACT 1961 REVISED. Updated to 13 April 2017

NOT FINAL UNTIL TIME EXPIRES TO FILE REHEARING MOTION AND, IF FILED, DETERMINED IN THE DISTRICT COURT OF APPEAL

Commonwealth of Kentucky Court of Appeals

IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO

SUPREME COURT OF ARKANSAS No.

Chapter II, Book III, Code Civil Of Intentional and Unintentional Wrongs

Civil Law is known as Private Law. Regulates disputes between individuals; between parties; and between individuals and parties.

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON. ) Appeal No. 02A CV-00237

BROWN & PARTNERS LLP TORT SUMMARIES FEBRUARY 2016

8 of 27 DOCUMENTS. ROBERT E. NUNEZ, SECOND vs. CARRABBA'S ITALIAN GRILL, INC., & another Saugus Concessions, Inc., doing business as The Palace.

Indiana Rejoins Minority Permitting Negligent Hiring Claims Even Where Respondeat Superior is Admitted

NEW OHIO SUPREME COURT LIQUOR LIABILITY OPINION

as amended by Apportionment of Damages Amendment Act 58 of 1971 (RSA) (RSA GG 3150) came into force on date of publication: 16 June 1971 ACT

Strict Liability and Product Liability PRODUCT LIABILITY WARRANTY LAW

Case 2:13-cv BJR Document 111 Filed 06/03/15 Page 1 of 10 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE

JERYD ZITO NO CA-0218 VERSUS COURT OF APPEAL ADVANCED EMERGENCY MEDICAL SERVICES, INC. AND EMPIRE INDEMNITY INSURANCE COMPANY FOURTH CIRCUIT

Social Host's Liability: No More One for the Road in New Jersey - Kelly v. Gwinnell

IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE Assigned on Briefs October 31, 2002

STATE OF MICHIGAN COURT OF APPEALS

EMPLOYMENT RELATIONSHIP LIABILITY OF EMPLOYER FOR NEGLIGENCE IN HIRING, SUPERVISION OR RETENTION 1 OF AN EMPLOYEE.

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FIFTH DISTRICT JANUARY TERM v. Case No. 5D

LIABILITY CHRONICLE. Editor: Stephen J. Marshall The Liability Newsletter of Franklin & Prokopik. Dram Shop Liability & Social Host Liability

JOINT TORTFEASORS UNDER RHODE ISLAND LAW

Monica Vickery sought review of the court of appeals. damages in her defamation suit against the mother and sister of

Edited'by: Uniting Plaintiff, Defense, Insurance, and Corporate Counsel to Advance the Civil Justice System

AN UNFAIR ALLOCATION OF FAULT AND LIABILITY: A

American Tort Reform Association 1101 Connecticut Avenue, NW Suite 400 Washington, DC (202) Fax: (202)

STATE OF MICHIGAN COURT OF APPEALS

10 AN ACT to amend and reenact of the Code of West Virginia, 1931, as amended, relating

Casebook pages Chapter 9: Battery, Assault & False Imprisonment. Battery

IN THE COURT OF APPEALS OF TENNESSEE AT JACKSON MAY 20, 2009 Session

CASE NO. 1D Caryn L. Bellus and Bretton C. Albrecht of Kubicki Draper, P.A., Miami, for Appellant.

Board of Claims -- Limitation on damage awards -- Hearing officers -- Asbestos related claims. (1) A Board of Claims, composed of the members

IN THE CIRCUIT COURT OF JEFFERSON COUNTY, ALABAMA BIRMINGHAM DIVISION ) ) ) ) ) ) ) ) )

[Until this opinion appears in the Ohio Official Reports advance sheets, it may be cited as Johnson v. Montgomery, Slip Opinion No Ohio-7445.

November/December 2001

Massachusetts Premises Liability

CHAPTER 107 CONTRIBUTORY NEGLIGENCE AND JOINT WRONGDOERS

170 S.E. 346 (S.C. 1933) 170 S.C. 286 TYGER RIVER PINE CO. v. MARYLAND CASUALTY CO. No Supreme Court of South Carolina July 17, 1933

The Struggle to Preserve Tribal Sovereignty in Alabama David Smith Kilpatrick Townsend & Stockton, LLP. Introduction

Commonwealth Of Kentucky Court of Appeals

Commonwealth Of Kentucky. Court of Appeals

LAW REFORM (TORTFEASORS CONTRIBUTION, CONTRIBUTORY NEGLIGENCE, AND DIVISION OF CHATTELS) ACT of 1952

Transcription:

I. Kentucky s Dram Shop Act KY DRAM SHOP MEMO II KRS 413.241 Legislative finding; limitation on liability of licensed sellers or servers of intoxicating beverages; liability of intoxicated person (1) The General Assembly finds and declares that the consumption of intoxicating beverages, rather than the serving, furnishing, or sale of such beverages, is the proximate cause of any injury, including death and property damage, inflicted by an intoxicated person upon himself or another person. (2) Any other law to the contrary notwithstanding, no person holding a permit under KRS 243.030, 243.040, 243.050, nor any agent, servant, or employee of the person, who sells or serves intoxicating beverages to a person over the age for the lawful purchase thereof, shall be liable to that person or to any other person or to the estate, successors, or survivors of either for any injury suffered off the premises including but not limited to wrongful death and property damage, because of the intoxication of the person to whom the intoxicating beverages were sold or served, unless a reasonable person under the same or similar circumstances should know that the person served is already intoxicated at the time of serving. (3) The intoxicated person shall be primarily liable with respect to injuries suffered by third persons. (4) The limitation of liability provided by this section shall not apply to any person who causes or contributes to the consumption of alcoholic beverages by force or by falsely representing that a beverage contains no alcohol. (5) This section shall not apply to civil actions filed prior to July 15, 1988. [ ] 2. Does the KY Dram Shop Act create a separate cause of action? In all likelihood, yes. The issue has not been specifically litigated in the appellate courts (and it doesn t help that the statute itself is silent as to whether it creates a private right of action), but two Kentucky Supreme Court cases and one Court of Appeals case concerning the Dram Shop Act makes it reasonably clear that the Act creates a separate, statutory cause of action. All three cases involved motor vehicle accidents.

A. DeStock v. Logsdon, 993 S.W.2d 952 (Ky.1999) KRS 413.241(3) declares the intoxicated person to be primarily liable for injuries to third persons. This makes the dram shop secondarily liable and therefore entitled to cross-claim for indemnity against the intoxicated person. DeStock No. 14, Inc. v. Logsdon, 993 S.W.2d 952, 958 (Ky.1999). According to the Kentucky Supreme Court, the injured party can sue to recover from either the intoxicated person or the dram shop, or both. Id. The dram shop is entitled to indemnity against the intoxicated person for injuries to third persons, but not entitled to indemnity for the separate (statutory) tort of selling alcohol to a person when a reasonable person under the same or similar circumstances should know that the person served is already intoxicated at the time of serving. KRS 413.241(2). In DeStock, the injured parties had settled with the drunken patron prior to trial. DeStock, 993 S.W.2d at 954. In its discussion of the Dram Shop Act in relation to KRS 411.182(1), 1 the Court made a point of saying that the settlement between the intoxicated person and the injured parties did not relieve the tavern owner of liability because the tavern owner is regarded as a separate tortfeasor. Id. at 959. This language in the context of discussing the Dram Shop Act strongly suggests that the Court recognizes that the Dram Shop Act creates a separate tort (i.e., negligently selling alcohol to intoxicated persons.) That the DeStock Court did not specifically state outright that the Dram Shop Act creates a separate right of action is not a surprise, given that the issue was not raised by the parties in DeStock. DeStock outlines the trial procedure thus: If a jury finds that (1) the dram shop sold intoxicating beverages to a patron when a reasonable person under the same or 1 which requires apportionment in all tort actions. 2

similar circumstances should have known that the patron was already intoxicated, and (2) such was a substantial factor in causing the patron to be intoxicated at the time of the accident, and (3) the patron s intoxication was a substantial factor in causing the third parties injuries, then the dram shop will be found liable. DeStock, 993 S.W.2d at 960. Again, the Kentucky Supreme Court did not specifically state the dram shop would be liable under the Dram Shop Act, but given that the first factor delineated by the Court exactly reflects the language of KRS 413.241(2), no other interpretation is reasonable. The point: In addition to recovering from the intoxicated person, a plaintiff could recover from a tavern found to be secondarily liable under the Dram Shop Act, although the tavern would then be entitled to recover from the intoxicated person any monies it paid to the injured party. Id. B. Sixty-Eight Liquors, Inc. v. Colvin, 118 S.W.3d 171 (Ky.2003) In Sixty-Eight Liquors, Inc. v. Colvin, 118 S.W.3d 171 (Ky.2003), the Kentucky Supreme Court noted that the Dram Shop Act clearly creates a civil cause of action for a minor against a dram shop that sells him alcohol because such is not a legal sale. Id. at 175. The plain language of the Dram Shop Act therefore suggests that both (1) the sale of alcohol to a minor and (2) the sale of alcohol to an intoxicated person create civil liability under the Act: In fact, sections (1) and (3) could never have been intended to completely immunize dram shops from liability; for even the original version of House Bill 570 did not purport to abrogate dram shop liability with respect to a sale or service to a minor. There is no reason to assume that the legislature intended one result with respect to a sale or service to a minor and a different result with respect to sale or service to an intoxicated person. 3

Sixty-Eight Liquors, 118 S.W.3d at 175, citing DeStock No. 14, Inc. v. Logsdon, 993 S.W.2d 952, 957 (Ky.1999) (emphasis added). The Kentucky Supreme Court noted further noted in Sixty-Eight Liquors that the statutory assignment of proximate cause requires that the purchaser be over the age for lawful purchase. If the purchase is lawful and a reasonable seller would not believe the purchaser to be intoxicated, the plain language of sections (1) and (2) relieves a dram shop of liability. A legal sale is required for a dram shop to be shielded from liability under KRS 413.241. Sixty-Eight Liquors, Inc. v. Colvin, 118 S.W.3d 171, 175 (Ky.2003) (emphasis added). Thus, the Kentucky Supreme Court in Sixty-Eight Liquors has again suggested (without stating outright, because the issue was not raised by the parties) that the sale of alcohol to a tavern patron when a reasonable person under the same or similar circumstances should know that the person served is already intoxicated at the time of serving is separate, tortious conduct for purposes of KRS 413.241, the Dram Shop Act. C. Jackson v. Tullar, 285 S.W.3d 290 (Ky.App.2007) The issue of suing a dram shop based on a theory of secondary liability did not appear before the appellate court until 2007, and has not yet been addressed by the Kentucky Supreme Court. Jackson concerned apportionment of liability between the intoxicated tortfeasor and the dram shop, and concluded that such apportionment was prohibited. Jackson v. Tullar, 285 S.W.3d 290, 297 (Ky.App.2007). Importantly, Jackson states that apportionment between the intoxicated person and the dram shop is not appropriate because the actions that give rise to liability -- directly causing injury and improperly serving alcohol to someone who later causes injury, respectively -- do not constitute concurrently negligent acts. Rather, they are 4

separate and independent actions of two fundamentally different characters. Id. at 296 (emphasis added). Notably, if there is more than one dram shop, as was the case in Jackson, there can be apportionment of liability between the dram shops themselves. Multiple dram shops that violate KRS 413.241 would have committed similar acts that would have had a similar relationship to a plaintiff's ultimate injury. In light of this similarity of circumstance and character, liability among multiple dram shops is properly apportioned under comparative fault principles. Id. at 297. The Jackson court outlined the trial procedure in the same manner as the DeStock court: First, the jury must determine the percentage of fault attributable to the drunken patron. Next, the jury could consider whether the elements under KRS 413.241 were satisfied such that the dram shop could be held secondarily liable. Id. at 296. Accordingly, once a jury determines that the elements under KRS 413.241 are satisfied such that either or both dram shops could be held secondarily liable, the jury should be instructed to apportion that liability between them based on the evidence presented. Specifically, the jury should be instructed to determine to what degree the sale or service of alcohol by each dram shop was a substantial factor in causing the tortfeasor's intoxication at the time of the accident. Id. at 297. The Jackson court then cites to DeStock at page 960, where the DeStock court outlines the trial procedure (regarding indemnity) described on page 2, above. [ ] 5