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Keywords

defendantdamagesnegligenceliabilitystatuteappealtrialsummary judgmentcorporation
plaintiffdefendantdamagesnegligencestatutetrialsummary judgmentcorporation

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Slade v. Smith’s Management Corp., 119 Idaho 482, 808 P.2d 401

Facts

Scott Slade, a nineteen-year-old pedestrian, was fatally injured when he was struck by a vehicle driven by Donald Westfall, who was intoxicated after consuming alcohol at a company-sponsored picnic. The picnic, organized by Smith's Management, Inc., featured alcoholic beverages that were freely available to attendees without supervision. The Slades sought damages for their son's death and incurred significant medical and funeral expenses. The district court ruled in favor of the defendants, leading to the Slades' appeal.

Scott Slade, a single youth aged nineteen years, was fatally injured on being struck by a motor vehicle being operated by an intoxicated driver, defendant Donald Westfall.

Issue

Did the district court err in granting summary judgment in favor of Smith's Management Corporation and Smith's Employees Association, specifically regarding the liability for providing alcohol to an obviously intoxicated person and the applicability of respondeat superior?

Whether the district court erred in granting summary judgment in favor of Smith's Management Corporation and Smith's Employees Association?

Rule

Under Idaho law, a violation of I.C. § 23-605, which prohibits the dispensing of alcohol to an intoxicated person, constitutes negligence per se, and liability may arise from the negligent provision of alcohol to a driver who subsequently causes injury or death.

In Idaho, the violation of a statute is negligence per se.

Analysis

The Supreme Court of Idaho determined that the district court had erred in granting summary judgment because there were genuine issues of material fact regarding whether Smith's Management had violated the statute by providing alcohol to Westfall, who was obviously intoxicated. The court emphasized that the question of liability should be resolved by a jury, as the facts presented could support a finding of negligence against the defendants for their role in the events leading to Slade's death.

The plaintiffs established as a triable issue that I.C. § 23–605 was violated, and that they were and are entitled to go to trial where the parties may introduce evidence, pro and con, as to causation and damages.

Conclusion

The Supreme Court reversed the district court's summary judgment in favor of the defendants, allowing the Slades to present their case to a jury.

We are constrained to hold that, under the facts alleged at this stage of the proceedings, the question is not one of law but of fact, and should be resolved not by the court but the jury.

Who won?

The Slades prevailed in the appeal because the Supreme Court found that there were genuine issues of material fact that warranted a trial, particularly regarding the alleged violation of the statute prohibiting the sale of alcohol to intoxicated persons.

The Supreme Court reversed the district court's summary judgment in favor of the defendants, allowing the Slades to present their case to a jury.

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