LaGuire v. Kain

Although we agree with the majority’s conclusion that the minor’s estate has no cause of action under Michigan’s Liquor .Control Act, as amended in 1986,1 we are unable to agree that the family of the minor has no cause of action.

The statute does not contain language that specifically suggests that the family members of an imbibing minor ought not be deemed individuals who suffer damage as a result of the minor’s having unlawfully obtained alcoholic liquor. The majority’s conclusion requires the assumption that the Legislature indirectly eliminated an historically recognized cause of action…