Juliano v. Simpson

We are asked to enlarge the scope of social host under our common law by extending a duty of care to an underage host who does not supply alcohol to underage guests, but provides a location where they are permitted to consume it. For the reasons stated herein, we decline to do so, and reaffirm that liability attaches only where a social host either serves alcohol or exercises effective control over the supply of alcohol.3

1. Background. Sixteen year old Rachel Juliano suffered seri-ous injuries when the automobile in which she was a passenger struck a utility pole. She and the driver of the…