## Facts

- On July 28, 1997, Texas residents Angelina Rios, Katherine Young, Joshua Young, and Seth Young were traveling westbound on Interstate 10 near Vinton, Louisiana.
- Chris Dewayne West drove eastbound on I-10, crossed the median into oncoming traffic, and struck the plaintiffs’ vehicle head-on.
- Rios, Katherine Young, and Seth Young (18 months old) died at the scene or en route to the hospital; Joshua Young and West survived but suffered severe injuries.
- Approximately 1.5 hours after the collision, testing showed West’s blood-alcohol concentration was 0.259.
- Before the crash, West spent several hours gambling and drinking aboard the PLAYERS III, a riverboat casino operating on navigable waters near Lake Charles, Louisiana, owned and operated by Players Lake Charles, L.L.C. and related casino entities.
- While gambling, West received multiple complimentary items (“comps”) from the casino; plaintiffs alleged at least some were used to obtain alcoholic drinks.
- Plaintiffs sued the casino entities in federal court, alleging the casino negligently served (or facilitated service of) alcohol to West when it knew or should have known he was intoxicated and that it was reasonably foreseeable he would drive and endanger others after leaving the vessel.
- Defendants moved for summary judgment, arguing Louisiana substantive law governed and barred dram-shop-type liability for alcohol providers.

## Issues

1. Whether admiralty jurisdiction applied to negligence claims tied to alcohol service on a casino vessel on navigable waters.
2. Whether the court should treat general maritime law (and not Louisiana’s statutory limits on alcohol-provider liability) as supplying the governing negligence standards for plaintiffs’ claims.
3. Whether defendants were entitled to summary judgment on duty, foreseeability, and proximate-cause grounds, including the argument that West’s decision to drive intoxicated was a superseding cause as a matter of law.

## Decision

- The court held admiralty jurisdiction was proper because the alleged negligent conduct occurred on navigable waters and the claims had a sufficient connection to traditional maritime activity, including the potential to affect maritime commerce.
- The court declined to grant summary judgment based on defendants’ argument that Louisiana law categorically foreclosed liability, concluding defendants had not shown they were entitled to judgment as a matter of law on the governing standards and their application to the record.
- The court found the summary-judgment record raised triable questions about (i) West’s level of intoxication while aboard the PLAYERS III, (ii) whether casino personnel served or enabled continued service of alcohol when West appeared intoxicated, and (iii) whether injury to motorists after West left the vessel was reasonably foreseeable.
- The court also declined to rule, as a matter of law at the summary-judgment stage, that West’s intoxicated driving necessarily broke the causal chain; proximate cause and any superseding-cause theory depended on fact questions for a jury.
- Defendants’ motion for summary judgment was denied.

## Legal Principles

- Admiralty tort jurisdiction may exist when the alleged wrongful conduct occurs on navigable waters and the claim bears a sufficient connection to maritime activity, including a potential disruptive effect on maritime commerce.
- In admiralty, negligence is measured by reasonable care under the circumstances; foreseeability informs the existence and scope of any duty and proximate cause.
- Summary judgment is appropriate only when there is no genuine dispute of material fact and the movant is entitled to judgment as a matter of law; the court views the evidence in the nonmovant’s favor.
- Questions of duty, foreseeability, proximate cause, and whether an intervening act is a superseding cause are often fact-dependent and may be inappropriate for resolution on summary judgment where the record supports competing inferences.

## Conclusion

Young held that admiralty jurisdiction covered negligence claims arising from alleged over-service of alcohol aboard the PLAYERS III riverboat casino and denied the casino defendants’ summary-judgment motion because the governing liability standards and the record left genuine disputes for trial on intoxication, notice, foreseeability, and causation in connection with the fatal Louisiana highway collision.


Young v. Players Lake Charles, L.L.C., 47 F. Supp. 2d 832 (1999)