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.