## Facts

- Randall Burkhead was served alcoholic beverages at two licensed establishments: Main Street Tap (operated by William D. Craig) and later Southfork Restaurant & Lounge (operated by Gary and Glenda Rogers).
- At Southfork, Burkhead refused to leave; a Southfork employee called the police.
- Officer Timothy A. Chapman responded to the call and was injured while arresting Burkhead.
- Chapman alleged Burkhead’s intoxication, caused by the illegal service of alcohol, led to the events resulting in Chapman’s injuries.
- Chapman sued the licensees under Iowa Code § 123.92 (1985) (dramshop liability).
- The district court granted summary judgment to the Rogers based on the fireman’s rule and denied Craig’s summary judgment motion; only the judgment for the Rogers was appealed.

## Issues

1. Whether Iowa should abolish the fireman’s rule, including in dramshop actions involving on-duty police officers injured while responding to calls.
2. Whether applying the fireman’s rule to bar an on-duty police officer’s dramshop recovery violates equal protection under the United States or Iowa Constitutions.
3. Whether the fireman’s rule applies to bar Chapman’s dramshop claim against the Rogers where his injury occurred while responding to a call triggered by Burkhead’s conduct at their premises.

## Decision

- The Supreme Court of Iowa affirmed summary judgment for the Rogers.
- The court declined to abolish the fireman’s rule and reaffirmed its use in appropriate dramshop cases.
- The court rejected Chapman’s equal protection challenge under rational-basis review.
- The court held the fireman’s rule barred Chapman’s claim because the injury arose from responding to the same conduct that created the need for police assistance at Southfork.

## Legal Principles

- Under Iowa’s fireman’s rule, an on-duty police officer may not recover in tort when the claim is grounded on the same conduct that created the need to call for the officer’s assistance.
- The rule does not apply when the officer is engaged in law enforcement activity unrelated to the violation that required the officer’s presence.
- Treating on-duty public-safety officers differently from the general public for purposes of tort recovery does not violate equal protection where no suspect class or fundamental right is involved and the classification is rationally related to legitimate governmental interests (including allocating job-related risk and avoiding duplicative compensation).

## Conclusion

The Iowa Supreme Court held that the fireman’s rule barred an on-duty officer’s dramshop claim against a licensee when the officer’s injury occurred while responding to a call prompted by the intoxicated patron’s conduct at the licensee’s premises, and it upheld the rule against an equal protection challenge.


Chapman v. Craig, 431 N.W.2d 770 (Iowa 1988)