James Rowland, Jr. v. Nancy Christian Case Brief

Summary of James Rowland, Jr. v. Nancy Christian, 69 Cal. 2d 108; 443 P.2d 561; Supreme Court of California [1968]

Facts: On November 30, 1963, plaintiff Rowland entered an apartment at the invitation of defendant Christian. While using the restroom, the porcelain handle of one of the water faucets broke in his hand, severing tendons and the medial nerve in his right hand. Plaintiff incurred medical and hospital expenses.

It was found that on November 1, 1963, plaintiff had told the lessors of her apartment that the water faucet knob was cracked and should be replaced. It was not clear from the complaint whether the crack in the faucet handle could have been discovered through an ordinary inspection, or whether it was concealed.

Plaintiff argued that defendant had been aware of the dangerous condition for approximately two weeks and hadn’t fixed it, and that he had informed her immediately before he was going to use the restroom and she didn’t warn him of the danger.

Defendant motioned for summary judgment, arguing that plaintiff was a social guest in her apartment and that he had used the bathroom on a prior occasion. She also alleged contributory negligence and assumption of the risk on the part of plaintiff.

History: The trial court granted summary judgment in favor of defendant Christian. Plaintiff appealed.

Issue: Should plaintiff, a social guest, be allowed to recover damages for personal injuries caused by a defective bathroom fixture in an apartment occupied by defendant?

Ruling: Yes. The Supreme Court of California reversed the trial court’s summary judgment.

Rule/Analysis: A social guest should be entitled to a warning of a dangerous condition so that he can take precautions to protect himself from injury.

Summary: The California Supreme Court felt that a person’s life or limb doesn’t become less worthy of protection under the law just because of his status as a trespasser, licensee, or invitee. Reasonable people don’t normally vary their conduct based upon these different types of status and it is unreasonable to focus upon that when determining the landowner’s duty of care.

The court took several items into consideration when making this decision, such as foreseeability of the injury. It would not have been difficult for defendant Christian to warn plaintiff of the danger [balance of utility versus risk of harm], either. The court felt that it was the duty of the landowner/defendant to exercise reasonable care for the protection of the licensee/plaintiff. The court, using these facts, reversed the judgment against the plaintiff.

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