Reeder v. Daniel

in which Justice HECHT, Justice OWEN, Justice BAKER, Justice JEFFERSON, and Justice RODRIGUEZ join.

Seventeen-year-old Jeff Lawson struck and injured Andrew Daniel after drinking beer at a party that Tom and Pam Reeder’s teenage son Tyler hosted. We must decide whether Daniel may recover against Tyler, as a social host, for injuries Lawson caused. The court of appeals recognized a negligence per se civil cause of action where one violates the criminal statute that prohibits furnishing alcohol to minors.1 But the Legislature has not expressly created a civil cause of action against social hosts…