Summary of Rowland v. Christian, S. Ct. California, 
Rejection or Merging of Categories
Relevant Facts: Pl was a guest in the apartment of the df. He asked to use the bathroom and while there was injured when a cracked handle on the basin broke, severing tendons and nerves on his hand. Df had known for two weeks and had notified the owner, but said nothing to her guest.
Legal Issue(s): Whether the rules of trespasser, licensee, or invitees, apply when addressing liability for fault to either the owner or host?
Court’s Holding: Negligence applies.
Procedure: Pl appeals summary for df Christian. Reversed.
Law or Rule(s): A man is liable for injuries caused by his carelessness or for a breach of a duty.
Court Rationale: The common law imposes on owners and occupiers of land a single duty of reasonable care in all circumstances. Liability should not be based upon the status of whether the injured party is a trespasser, licensee, or invitee. The factors involved with each do not reflect what factors should be used to determine liability . To focus on that status of the injured party in that matter to determine whether the landowner has a duty of care is contrary to our modern social mores and values. Failure to warn a guest or licensee of a potentially dangerous situation, whether landowner or possessor, is to subject that a party to an unreasonably risk of harm when the concealed condition is known or likely to be known by the landowner or possessor.
Plaintiff’s Argument: The host breach a duty that a reasonably and prudent person would exercise in similar situations; failure to warn of a known dangerous condition.
Defendant’s Argument: The injured party was either a licensee or invitee and as such different rules apply to determine the level if any liability.