## Facts

- An adult homeowner hosted a high school graduation party at her home in Warwick, Rhode Island, for her daughter.
- The gathering was large (roughly 70 attendees), largely teenagers and young adults (about ages 17–20), with invitations spread informally.
- The plaintiff attended and alleged alcohol was available at the party, including beer kegs, and that underage guests consumed alcohol.
- A confrontation occurred during the party involving one guest and some of the plaintiff’s friends.
- After the altercation, that guest left and returned with another person who carried a baseball bat allegedly obtained from the guest.
- The returning person struck the plaintiff with the bat, causing severe injuries including brain damage.
- The plaintiff alleged the host either furnished alcohol to minors or had actual knowledge of underage drinking on the premises and failed to take reasonable measures to protect guests from foreseeable harm.
- The trial court granted summary judgment to the host, ruling she owed no duty to protect the plaintiff from the assailant’s attack, and entered partial final judgment as to the host.
- The plaintiff appealed; only the host was before the appellate court.

## Issues

1. Whether an adult social host who provides alcohol to underage guests, or has actual knowledge that minors are drinking on the premises, owes a duty of reasonable care to protect a guest from physical assault by expected attendees (or those acting at their behest).
2. Whether disputed facts concerning the host’s provision/knowledge of underage drinking, foreseeability of violence, and causation preclude summary judgment.
3. Whether the assailant’s criminal act was a supervening cause breaking the causal link as a matter of law at the summary-judgment stage.

## Decision

- The appellate court vacated the summary judgment and remanded for further proceedings.
- It held that, if the host provided alcohol to underage partygoers or had actual knowledge of underage drinking on her property, she had a duty to exercise reasonable care to protect the plaintiff from assault by persons expected to be in attendance or those acting at their behest.
- It concluded the record contained genuine disputes of material fact, including who supplied alcohol, what the host knew about underage consumption, what she knew about the earlier altercation, and what reasonable steps were available.
- It ruled that causation questions—whether the injuries were causally related to the host’s conduct and whether the assailant’s act was supervening—were for the fact-finder and could not be resolved on summary judgment.

## Legal Principles

- On summary judgment, courts must view the evidence in the light most favorable to the nonmoving party and may not resolve credibility or weigh competing accounts.
- An adult social host who furnishes alcohol to minors, or who has actual knowledge that underage drinking is occurring on the premises, must exercise reasonable care to protect guests from physical assaults by expected attendees or persons acting at their behest.
- Foreseeability informs duty; a large gathering involving underage drinking may create foreseeable risks of violent misconduct, particularly where tensions or an earlier altercation occurred.
- Whether a third party’s criminal assault constitutes a supervening act that breaks causation is generally a fact question when foreseeability and the host’s conduct are disputed.

## Conclusion

The court held that a social host’s alleged provision of alcohol to minors, or actual knowledge of underage drinking, can create a duty to take reasonable steps to protect guests from foreseeable assaults by other attendees, and that disputed facts on duty, foreseeability, and causation required trial rather than summary judgment.


Martin v. Marciano, 871 A.2d 911 (R.I. 2005)