Lesnau v. Andate Enterprises, Inc.

We are asked to construe the standard of liability required under R.C. 4399.18(A)(3), Ohio’s Dram Shop Act. The statute codifies the longstanding rule limiting the liability of a liquor permit holder for injuries caused by an intoxicated person except under certain limited circumstances. The central dispute before this court is whether the statute requires that the liquor permit holder have actual knowledge of the underage status of the purchaser before liability may be imposed for injuries to a third person.

*468Factual Background

Appellee Donald W. Lesnau, Administrator of the Estate of Janice…