Summary of Stachniewicz v Mar-Cam Corp, Court and State, Year
Relevant Facts: Pl (Stach) a patron of a drinking establishment was injured in a fight therein. A group of Native Americans sitting in an adjacent booth became disruptive when Pl guests refused to allow a friend’s wife to dance with them. The bartender warned PL not to start any trouble with them. The Native American’s pushed down a member of the Pl’s party and the fight began. Pl was found lying just outside. He suffered amnesia and could remember nothing. The n.a. had been drinking in the bar for 2.5 hours before the fight.
Legal Issue(s): Whether violations of statute constitute negligence as a matter of law.
Court’s Holding: Yes
Procedure: Jury returned a verdict for Df. PL appealed. Reversed and remanded for trial.
Law or Rule(s): A violation of a statute constitutes negligence as a matter of law when the violation results in an injury to a member of a class of persons intended to be protected, and when the harm is the kind which the statute was enacted to prevent.
Court Rationale: The Act concerns matters having a direct relation to the creation of physical disturbances in bars which would create a likelihood of injury to customers. The act seeks to prevent abusive conduct and drunken clientele which results in serious injuries to customers. The bar owner’s breach of duty to protect his patrons from harm resulting from a drunken brawl is negligence. Pl was within a class intended to be protected, and the harm caused was the kind the statute intended to prevent.
Plaintiff’s Argument: The Pl was injured in a bar, by customers who were drunk.
Defendant’s Argument: The standard of care is the reasonable care that a bartender similarly situated would exercise. The Pl was injured outside the bar.