Rowland v. Christian

Citation. Rowland v. Christian, 69 Cal. 2d 108, 443 P.2d 561, 70 Cal. Rptr. 97, 1968 Cal. LEXIS 231, 32 A.L.R.3d 496 (Cal. 1968)

Brief Fact Summary. The Plaintiff, Rowland (Plaintiff), was injured when a cracked handle on a water faucet broke while Plaintiff was using the Defendant, Christian’s (Defendant) bathroom. Defendant knew of the faulty handle, but failed to inform Plaintiff. Plaintiff filed suit for injuries.

Synopsis of Rule of Law. California abolishes the traditional classifications of trespassers, licensees and invitees and instead applies ordinary principles of negligence in these cases.

Facts. Plaintiff was a social guest at Defendant’s apartment. Plaintiff used Defendant’s bathroom, where he was injured when a cracked handle on the water faucet broke and severed tendons and nerves in his right hand. Evidence showed that Defendant had known the handle was cracked for two weeks, but failed to inform Plaintiff of its condition. Plaintiff appeals from a summary judgment for the Defendant.

Issue. Was the trial court correct in granting summary judgment for the Defendant based on Plaintiff’s status as a licensee?

Held. No. Judgment reversed.
* Based on historical considerations placing land ownership in a disproportionately high place, this and other courts have generally departed from the concept that an individual is liable for injuries caused by his carelessness. The categorization of injured parties as trespassers, licensees, and invitees produces confusion and conflict and are not justified in our modern society.
* The traditional classifications do not reflect the major factors, which should determine when immunity should be conferred. Some of these factors include the closeness of the connection between the injury and the defendant’s conduct, the moral blame attached to defendant’s conduct, the policy of preventing future harm, and prevalence and availability of insurance.
* The Court overturns these traditional classifications and instead will apply ordinary principles of negligence in cases such as the one at hand. In the present case, viewing the facts in a light most favorable to Plaintiff, a trier of fact could reasonably have concluded that a failure to warn or repair the condition constituted negligence.

Dissent. In the dissenters view, it was not proper for the majority to overturn a long standing, well supported rule without the instruction of the Legislature. The previous rules provided stability and predictability and supplied a reasonable and workable approach. The new approach will require decisions on a case-by-case basis and could open the door to potentially unlimited liability.

Discussion. There is considerable agreement amongst modern courts that the general negligence standard should be applied to all persons invited or permitted on the premises. However, there is less agreement regarding the treatment of trespassers.