Case: Rowland v Christian

69 Cal.2d 108

Parties: Plaintiff - Rowland (guest)

Defendant - Christian (landowner)

Procedural History: Summary judgment for defendant.

Facts: Rowland was a guest in Christian's apartment, who while using the
restroom was injured when the porcelain handle of the faucet broke in his hands.
Christian knew of the crack, and had informed the landlord of it, but did not warn
Rowland. The trial court granted summary judgment for defendant, following the
rule that a licensee or social guest was obliged to take the premises as he or she
found them, and the possessor of the premises owed a duty only to refrain from
wanton or willful injury.

Issue: What duty does a landowner owe a social guest?

Reasoning: The appellate court reversed the summary judgment, holding that an
increased regard for human safety justified a retreat from the trial court's
position. The court held that a social guest such as plaintiff was entitled to a
warning of a dangerous condition so that he, like the host, would be in a position
to take special precautions when he came into contact with it.

Dissent - argues in favor of the classical classifications. Allow landowner

unfettered use of his/her land.

Notes

After Rowland, many jurisdictions have abolished the distinctions btwn invitees
and licensees. Other (incl. NY), have abolished the traditional classifications.

Eliminating the traditional entrant categories.