Rowland v. Christian
69 Cal.2d 108, 70 Cal.Rptr. 97, 443 P.2d 561 (1968)
Rowland was visiting Christian. He went to the bathroom
and a porcelain bathroom faucet broke in his hand. He sued for negligence.
Christian knew that the faucet was cracked, yet did
nothing to repair it, nor did he warn Rowland to be careful.
The Trial Court granted summary judgment to Christian and
dismissed the case. Rowland appealed.
The Appellate Court reversed.
The Appellate Court looked to the California Civil Code,
which said that "everyone is responsible not only for the result of
his willful acts, but also for an injury occasioned to another by his
want of ordinary care or skill in the management of his property..."
The Court noted that historically there are
special rules of liability regarding the possessor of property and
injuries to those they invited inside.
In this case, Rowland was an invitee, not a trespasser
or a licensee.
However, the Court felt that these distinctions
were irrelevant. The Court abolished the distinctions between invitees,
trespassers and licensees, and instead offered a blanket
standard of reasonable due care.
Is an injury to a trespasser worth less than an
injury to an invitee?
Reasonable people do not vary their conduct depending on
how the person came to their property.
Only a few States have followed California's abolition of
the distinctions between different categories of people that enter a
person's land.
