Rowland v. Christian

Brief Fact Summary.

A guest was injured by a broken faucet which the host failed to warn him of, depriving him of his ability to exercise additional care.

Synopsis of Rule of Law.

A host doe not exercise reasonable care in failing to warn guests of dangerous conditions, preventing them from exercising the increased care that the host would.

Facts.

Defendant leased an apartment, which had a cracked cold water knob on the faucet in the bathroom.  She subsequently invited the Plaintiff to her apartment as a guest, whereupon he was injured while using the broken fixture.  His injuries included severed tendon and nerve in his right hand, and he had incurred medical expenses.  Plaintiff brought suit to collect damages on the grounds that Defendant was negligent in failing to exercise care in knowing that the fixture was broken (and dangerous) and failing to warn him of the danger.

Issue.

The substantive issue is whether the plaintiffs injury was a result of the defendants negligence?

Held.

Yes, a host aware of a dangerous condition is obligated to warn a guest of the condition so that they can exercise additional care.

Dissent.

Justice Burke, J., (joined by McComb, J.)

Justice Burke dissents from the majority on the grounds that the law of negligence and the duties required thereunder should differ based on the relationship between the plaintiff and the defendant.  He opines that the nature of the relationship should increase or decrease based on the social customs; a business open to the public should be subject to a different standard than a host entertaining a guest.  He dissents from the single standard set forth by the majority.

Discussion.

The Court found that the defendant knew the condition of the faucet, was aware that the defect was not obvious, that the plaintiff could not be expected to notice the condition, and that the defendant did not exercise reasonable care by eliminating the danger or warning the plaintiff of the condition of the faucet.  In reaching this conclusion, the Court considers the foreseeability of the harm, the probability of harm resulting, the closeness of the connection between the defendants conduct and the harm, the burden on the defendant of mitigating the harm, and public policy. The court concluded that under the facts pled, the requirements for a motion for summary judgement were not met.