Sproul v. Vallee (Nov. 21, 2025, No. A172205) __Cal.App.5th__ (2025 WL 3251224)
Plaintiff sued their neighbor, whose deceased husband assaulted one of the plaintiffs. Plaintiffs alleged that the defendant had a duty to control her husband’s violent conduct and to protect or warn neighbors about his aggressiveness. The trial court sustained defendant’s demurrer to all claims, and plaintiffs appealed.
The Court of Appeal affirmed because the defendant lacked “a special relationship with the decedent that involved the ability to control his conduct,” even though they were married. The court added that, even if a special relationship existed, the defendant did not owe a duty to protect the plaintiffs from her husband’s actions for several reasons, including the absence of any allegation that the wife knew her husband planned to cause harm, the unforeseeable nature of her husband’s behavior, and public policy considerations “against intruding on the marital relationship with an obligation owed to third parties.”
