Glynn v. Orange Circle Lounge (2024)
A customer at defendants’ bar became involved in an altercation with several of the bar’s other patrons. Security broke up the fight, and the customer and his assailants went their separate ways. One hour later, the customer encountered his assailants again in the parking lot of another business. Another fight ensued and the customer was stabbed to death. The customer’s parents sued the bar for wrongful death. The trial court granted defendants’ motion for summary judgment, concluding that defendants’ duty to the customer did not extend to the subsequent fight at another business location. Plaintiffs appealed.
The Court of Appeal affirmed. Although past cases have recognized a special relationship between bar proprietors and their customers, the tenuous nature of the connection between the bar’s conduct and the customer’s death, the absence of moral blame attached to the bar’s conduct, and the substantial burden that imposing a duty would place upon defendants and the community outweighed other factors favoring imposition of a duty. Thus, the court agreed with the trial court that the bar did not owe a duty to the customer in this circumstance.
