Summary
The Connecticut Appellate Court affirmed the trial court's grant of the defendant's motion to strike the plaintiffs' negligence and public nuisance claims. Relying on controlling precedent, the court held that a premises owner generally cannot be held liable for harms caused by adults who consume alcohol on the property but cause injury after leaving to drive on public roads. The court concluded that established legal principles deem the intoxicated driver's choice to consume alcohol and operate a vehicle as the sole proximate cause of the resulting crash.
Topics
Practice areas
Questions Presented
- Whether the trial court erred in granting the motion to strike the negligence claim.
- Whether the trial court erred in granting the motion to strike the public nuisance claim.
Holdings
- The trial court properly granted the defendant’s motion to strike the plaintiffs’ negligence claim.
- The trial court properly granted the defendant’s motion to strike the plaintiffs’ public nuisance claim.
Key quotations
“Our review of a trial court’s decision to grant a motion to strike is plenary. . . . This is because a motion to strike challenges the legal sufficiency of a pleading, and consequently, requires no factual findings by the trial court.” (at 10)
“An owner or possessor of property in this state generally cannot be held liable in negligence for harms caused by adults who consume alcohol on that property but cause injury only after leaving to drive on the public roads.” (at 12)
Factual background
Live Nation Worldwide operated the Xfinity Theatre where patrons were allowed to tailgate and consume alcohol in the parking lot. Jacob Coffey, a patron, became intoxicated, was denied entry to the concert, and later drove off the premises, colliding with a vehicle driven by the decedent, Luke M. Roux, causing fatal injuries. The plaintiffs alleged that Live Nation’s failure to control intoxicated patrons and to prevent Coffey from leaving the premises gave rise to negligence and public nuisance claims.
Procedural history
The plaintiffs filed an action in the Superior Court (Hartford Judicial District) alleging negligence and public nuisance. The trial court, before Judge Connors, granted Live Nation Worldwide’s motion to strike the negligence and public nuisance counts and entered judgment. The plaintiffs appealed to the Connecticut Appellate Court, which affirmed the trial court’s decision.