Daniels v. Carpenter

Summary

The Wyoming Supreme Court affirmed dismissal of a negligence complaint against homeowners arising from injuries caused by an intoxicated minor social guest who later drove a vehicle. The court held that the complaint failed to allege facts indicating that the homeowners provided or knew alcohol was provided, knew the minor became intoxicated, and knew or should have known he would soon drive. The court also affirmed denial of leave to amend because the plaintiff's oral motion was unsupported by facts justifying amendment.

Holdings

1. A mere allegation that parents or homeowners failed to supervise minor social guests does not, without more, create a duty to protect third parties from harm caused by an intoxicated minor driver. At minimum, the complaint must allege facts supporting that the defendants provided alcohol to the minor, or knew or should have known that alcohol was being provided; knew or should have known that the minor was drinking to the point of intoxication; and knew or should have known that the minor would soon drive an automobile.
2. The district court did not abuse its discretion in denying Daniels's oral motion for leave to amend because the motion did not identify proposed factual amendments and was an attempt to investigate and develop a possible claim after the limitations period, rather than a definite request to add allegations that would state a cause of action.

Questions Presented

1. Whether Wyoming law imposed a duty on the Carpenters to protect Daniels from harm caused by an intoxicated minor social guest under the facts alleged.
2. Whether the district court abused its discretion by denying Daniels's motion for leave to amend the complaint.

Disposition

affirmed