Rowland v. Christian, 69 Cal. 2d 108

Case citation

Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (1968), was a case

Legal case

A legal case is a dispute between opposing parties resolved by a court, or by some equivalent legal process. A legal case may be either civil or criminal...

 decided by the Supreme Court of California

Supreme Court of California

The Supreme Court of California is the highest state court in California. It is headquartered in San Francisco and regularly holds sessions in Los Angeles and Sacramento. Its decisions are binding on all other California state courts.-Composition:...

 that eliminated the categories of invitee

Invitee

In the law of torts, an invitee is a person who is invited to land by the possessor of the land as a member of the public or one who is invited to the land for the purpose of business dealings with the possessor of the land...

, licensee

Licensee

A licensee is someone who has been granted a licence.- Tort law :The term is used in the USA law of torts to describe a person who is on the property of another, despite the fact that the property is not open to the general public, because the owner of the property has allowed the licensee to enter...

, and trespasser

Trespasser

In the law of tort, property, and criminal law a trespasser is a person who commits the act of trespassing on a property, that is, without the permission of the owner. Being present on land as a trespasser thereto creates liability in the trespasser, so long as the trespass is intentional...

 when determining the duty of care

Duty of care

In tort law, a duty of care is a legal obligation imposed on an individual requiring that they adhere to a standard of reasonable care while performing any acts that could foreseeably harm others. It is the first element that must be established to proceed with an action in negligence. The claimant...

 owed by a possessor of land to the people on the land, replacing the classifications with a general duty of care.

Factual background

The plaintiff was a guest in the apartment of the defendant. The plaintiff requested to use the bathroom, and in the bathroom injured his hand on a broken water faucet handle. The defendant had complained to the landlord about the broken handle but did not warn the plaintiff. The trial judge granted summary judgment

Summary judgment

In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....

on behalf of the defendant, and the plaintiff appealed.

Decision

Common law distinctions between an invitee, licensee, and trespasser can determine the duty of care owed by a land possessor to the plaintiff. A duty of care to warn about the dangerous condition of area is owed to invitees and licensees under these distinctions, but not to trespassers. The California Supreme Court considered these classifications to be an unhelpful shortcut when determining negligence, and that a general duty of care should be owed to all visitors to land. The summary judgment for the defendant was reversed because the defendant should have warned the plaintiff of the broken handle.