## Facts

- Jamie and Anna Hicks hosted their wedding reception with alcohol available, including wine and champagne with dinner and later a hosted bar.
- Steven Hicks, Jamie’s 17-year-old nephew, attended and consumed alcohol at the reception; accounts conflicted on whether guests could serve themselves and whether hosts observed Steven drinking or appearing intoxicated.
- Around midnight, Steven left the reception driving his sister’s car.
- About 1:00 a.m., Steven collided with Timmy Reynolds; both Steven and Reynolds had blood alcohol levels of 0.17%.
- Reynolds suffered serious injuries and, with his family, sued the Hickses alleging negligence for furnishing alcohol to an underage person and for allowing him to become intoxicated.

## Issues

1. Whether social hosts who furnish alcohol to a minor owe a duty of care to third persons injured by the intoxicated minor.
2. Whether the criminal statute prohibiting furnishing alcohol to minors implies a civil cause of action (or negligence-per-se duty) for third-party victims injured by the minor.

## Decision

- The Washington Supreme Court affirmed summary judgment dismissing the claims against the Hickses.
- The court held social hosts who furnish alcohol to a minor owe no duty to third persons injured by that minor.
- Because the case failed on the threshold duty element, the court did not need to resolve disputed facts about whether the Hickses furnished alcohol to Steven or should have detected intoxication.

## Legal Principles

- Absent legislation to the contrary, Washington common law does not impose social-host liability to third parties for injuries caused by an intoxicated guest.
- A statute criminalizing furnishing alcohol to minors supports civil liability only within the class the statute principally protects; the statute’s primary protective purpose is the minor, not the general public.
- The existence of commercial vendor (dram-shop-type) liability does not require extending a comparable duty to social hosts; courts may treat vendors and social hosts differently based on regulatory design and practical differences in supervision and service.
- Expansion of alcohol-related tort duties, particularly for social-host contexts, is primarily a legislative policy decision rather than a judicial one.

## Conclusion

The court held that a third party injured by an intoxicated minor cannot recover in negligence from social hosts who furnished the minor alcohol because the hosts owe no duty to third-party victims under Washington law or the statute prohibiting furnishing alcohol to minors.


Reynolds v. Hicks, 134 Wash. 2d 491, 951 P.2d 761 (Wash. 1998)