Rowland v. Christian
Citation and Court
69 Cal. 2d 108 (1968), Supreme Court of California
Facts
Rowland was a social guest at Christian’s apartment. Christian was aware that her bathroom faucet handle was cracked and had notified her landlord but had not warned Rowland. Rowland was seriously injured when the faucet handle broke while he was using it. He sued Christian for negligence, and the trial court granted summary judgment for the defendant based on the traditional rule that a licensee could only recover for willful or wanton injuries.
Issue
Whether California should retain the common law categorization of entrants as invitees, licensees, and trespassers with differing duties owed to each, or replace it with a general negligence standard.
Holding
The California Supreme Court abolished the traditional tri-partite entrant classification system and held that landowners owe all entrants a general duty of reasonable care under the circumstances.
Rule / Doctrine
The common law categories of invitee, licensee, and trespasser create artificial distinctions inconsistent with the general principle that all persons owe a duty of ordinary care to avoid injury to others. California replaced these categories with a general negligence standard: a landowner must act as a reasonable person in view of all the circumstances, including the probability of injury, the seriousness of the injury, the burden of precaution, and the nature of the entrant’s purpose.
Significance
Rowland v. Christian is one of the most significant tort law cases of the twentieth century. It was among the first decisions to abolish the common law premises liability categories, and its multi-factor negligence analysis has been widely influential. It represents the high-water mark of the California court’s willingness to rationalize tort doctrine around general negligence principles.