## Facts

- A group of minors gathered socially; Scott Goosie and Phillip Worley went to a Weigels convenience store to buy beer.
- Goosie, under age 21, purchased beer; the clerk did not request proof of age.
- Goosie did not drink the beer; another minor, Anthony Kaiser, consumed it and became intoxicated.
- Kaiser drove Worley home, lost control, and crashed into a utility pole, seriously injuring Worley.
- Worley’s parents sued Weigels, alleging an unlawful sale to a minor in violation of Tennessee statutes and claiming the sale proximately caused Worley’s injuries.
- The trial court granted summary judgment to Weigels; the court of appeals reversed; the Tennessee Supreme Court granted review.

## Issues

1. Whether a commercial seller is civilly liable for injuries caused by an intoxicated minor driver when the seller unlawfully sold beer to a different minor who did not consume it, given statutes declaring consumption (not furnishing or sale) to be the proximate cause of alcohol-related injuries.
2. Whether criminal statutes prohibiting sales of beer to minors support a civil negligence claim despite the statutory proximate-cause allocation.

## Decision

- The Tennessee Supreme Court reversed the court of appeals and reinstated summary judgment for Weigels.
- The court held that, under the controlling statutes, the consumption of alcohol—not its sale or furnishing—is the proximate cause of injuries inflicted by an intoxicated person.
- Because the minor purchaser (Goosie) did not consume the beer that led to the injury, the statutory conditions for seller civil liability were not met.

## Legal Principles

- When a statute expressly allocates proximate cause in alcohol-related injury cases to consumption rather than furnishing or sale, courts apply that legislative determination in civil actions.
- A criminal prohibition on selling alcohol to minors does not, by itself, create broad civil liability where the legislature has limited civil causation and liability by statute.
- Common-law foreseeability-based negligence theories cannot be used to bypass an explicit statutory rule defining proximate cause and restricting alcohol-seller liability.
- Under the statutory scheme applied, seller civil liability is limited to defined circumstances tied to the minor purchaser’s consumption causing the injury, not to later consumption by a different person.

## Conclusion

The court held that an unlawful sale of beer to a minor did not support civil liability for third-party injuries where a different minor consumed the beer and caused the accident, because Tennessee law treats consumption—not sale—as the proximate cause for such injuries and confines seller liability to specific statutory conditions.


Worley v. Weigels, Inc., 919 S.W.2d 589 (Tenn. 1996)