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Increasing Accountability: Minors Now Included in Duty to Prevent Underage Drinking as Social Hosts

May 3, 2024

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In New Jersey, it has long been established that social hosts can be held liable for serving liquor to a visibly intoxicated minor, knowing that the minor will thereafter drive.  Such a social host would be liable for the injuries inflicted on an innocent third party as a result of the subsequent drunk driving of a minor.  Recently, the New Jersey Supreme Court has extended this liability to minor social hosts.

In Narleski, the estate of a 19-year-old man brought a wrongful death action after being killed in a motor vehicle accident.  The 19-year-old man was served alcohol at an underage host’s house and was the passenger in a vehicle driven by another guest at the party, who also was negligently served alcohol.  The estate originally sued the liquor store that sold alcohol to the host.  The liquor store filed a third-party complaint against the host and his parents, alleging that they were negligent in failing to supervise attendees and in enabling underage adults to consume alcohol.  Est. of Narleski v. Gomes, 244 N.J. 199, 237 A.3d 933 (2020).  The New Jersey Supreme Court held that the underage social host who negligently allowed the minors to drink alcohol on the host’s property was liable when the minor subsequently caused a car wreck that resulted in injuries. Id. 

Additionally, it is also important to note that the New Jersey Supreme Court does not draw a distinction between the host actively supplying the minors with alcohol and passively allowing minors to drink. “Should the line drawn for the imposition of a duty on the host depend on whether he poured the drink for his visibly intoxicated guest as opposed to whether he is a mute observer of his intoxicated guest's continued consumption of beer or vodka left on a table and swigged in cups provided by the host? The Dower court rejected that artificial distinction, and we do so here as well.” Id. Overall, the New Jersey Supreme Court made it clear that social hosts need to be extremely careful that they are not providing alcohol to minors and are not over-serving their guests.

Estate of Narleski v. Gomes
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