## Facts

- High school students organized a graduation “kegger” party on June 7, 1977; tickets were sold for $4 to cover beer, food, and music, and 15 kegs of beer were purchased.
- The party location was moved to a farm parcel on 109th Avenue that was one of several parcels leased for farming by Charles and Thelma Strunk; their son Dean Strunk helped with duties at the property.
- Charles and Thelma Strunk did not plan the party; late at night they learned from callers and people seeking directions that the party was on Strunk-leased property, and Charles drove to nearby parcels to investigate.
- Lisa Younce arrived around 11:30 p.m. with a friend who had bought tickets; during the party she was struck and injured by a car driven by another minor, Tamera Ferguson, on the 109th Avenue parcel.
- Younce sued Ferguson and the Strunks; the trial court classified Younce as a licensee on the Strunks’ property, found no breach of duty to a licensee, and dismissed the Strunks.

## Issues

1. Whether Washington should abandon the invitee/licensee/trespasser classifications in favor of a single reasonable-care standard for land possessors.
2. Whether Younce’s presence at a ticketed graduation party on the Strunks’ leased property made her an invitee rather than a licensee.
3. Whether the Strunks breached any duty owed to Younce under the applicable entrant classification.

## Decision

- The Supreme Court of Washington affirmed the dismissal of Charles, Thelma, and Dean Strunk.
- The court declined to replace the traditional invitee/licensee/trespasser framework with a unitary reasonable-care standard.
- The court held Younce was a licensee, not an invitee, because the event was a social gathering and her entry was not for a business purpose of the land possessors.
- Applying the licensee duty, the court found no evidence of willful or wanton conduct by the Strunks and no failure to warn of a latent, known condition of the premises.

## Legal Principles

- In Washington, an entrant’s status as invitee, licensee, or trespasser determines the duty owed by an owner or occupier of land.
- Invitee status generally requires entry connected to the land possessor’s business or land held open to the public for that purpose; payment that merely defrays social-event costs does not convert a social guest into an invitee.
- A land possessor’s duty to a licensee is limited to refraining from willful or wanton injury and warning of latent dangers the possessor actually knows about and the licensee is unlikely to discover.
- Injuries arising from third-party activity at a social gathering, without a concealed premises condition known to the possessor, do not alone establish breach of the licensee duty.

## Conclusion

The court kept Washington’s traditional entrant classifications and held that a graduation-party attendee who paid a small amount to offset event expenses was a licensee on the leased farm parcel; because the land possessors neither committed willful or wanton misconduct nor failed to warn of a known hidden premises danger, dismissal of the land-possessor defendants was affirmed.


Younce v. Ferguson, 724 P.2d 991 (Wash. 1986)