Reynolds v. Hicks

951 P.2d 761 (1998)

Facts

Jamie and Anna were married in 1988 in Seattle. Three hundred people attended the wedding including their underage nephew, Steven Hicks. Wine and champagne were served at the reception. A jury could have found that Steven consumed alcohol at the reception despite claims that the bar was hosted at all times. At midnight, Steven left the reception in his sister's car and was involved in an auto accident with Reynolds (P). P and his family alleged that Jamie and Anna (D) were negligent in serving alcoholic drinks to Steven. The suit against Steven and his sister was settled. Ds moved for summary judgment; Washington law does not extend social liability for furnishing alcohol to a minor to third persons injured by the intoxicated minor. Ps contend that a duty is owed by statutory authority RCW66.44.270. D was granted a summary judgment and appealed asking for allowance of a cause of action for third persons who are injured by an intoxicated minor against the social host.