Fugate v. Safeway Stores, Inc.

Plaintiff 1 brought this action for damages for personal injuries suffered in an automobile accident, alleging that defendant’s sale of beer to Tromblee, a minor, was a substantial factor in causing the accident. Defendant appeals from a judgment for plaintiff, assigning error both to the denial of its motion for a directed verdict and to the exclusion of evidence proffered by defendant regarding subsequent injuries to plaintiff. We reverse.

Tromblee, then 19 years old, purchased 12 cans of beer at defendant’s store shortly after 7:00 p.m. on April 8, 1991. After consuming that beer with his…