Jupin v. Kask

17 Mass. L. Rptr. 617
CourtMassachusetts Superior Court
DecidedMay 6, 2004
DocketNo. 020997
StatusPublished

This text of 17 Mass. L. Rptr. 617 (Jupin v. Kask) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jupin v. Kask, 17 Mass. L. Rptr. 617 (Mass. Ct. App. 2004).

Opinion

Fecteau, J.

The defendant has filed the above motion generally on the grounds that as an owner of real property at which she resides, she owes no duty to the innocent victim of a shooting that occurred by means of a firearm owned by her live-in companion, but which had been stolen and used by his adult son who did not reside with him or the defendant, notwithstanding her knowledge that firearms were being stored by her companion in her house. The plaintiff contends that as an owner of real properly, the defendant has a duty of care, concurrent with the owner of the firearm, to store it safely, and, in breach of such a duty, she is liable to third parties who are injured as a result. The plaintiffs case sets forth causes of action sounding in common-law negligence, negligence founded upon a breach of a safety statute, strict liability and public nuisance. For the following reasons the defendant’s motion for summaiy judgment is ALLOWED.

BACKGROUND

The following facts are taken from the summary judgment record and all material facts are undisputed.

On May 10, 1999, Lawrence M. Jupin (Officer Jupin), was shot and injured while in the course of his duties as a Westminster Police Officer in the Town of Westminster, Massachusetts. The plaintiff alleges that Officer Jupin was shot by Jason Rivers, the son of the defendant’s live-in boyfriend. The defendant, Sharon Kask (Kask), lives in Fitchburg, Massachusetts, with her boyfriend Willis Rivers (Mr. Rivers). Mr. Rivers’ adult son, Jason Rivers, is not related to Kask and did not reside with Kask and his father on the day of the shooting. Mr. Rivers kept his firearms in a cabinet fashioned with a lock in the cellar of Kask’s home. Kask contends that the cabinet was locked on the day of the shooting.

The plaintiff alleges that Jason Rivers stole the gun used in the shooting from his father’s gun cabinet by removing the screws on the gun cabinet, taking the gun, and then replacing the screws to cover up the theft. Neither Kask nor Mr. Rivers knew Jason Rivers had stolen a gun from the cabinet. Kask never used or handled any of the guns owned by Mr. Rivers in the time that he stored them in the cabinet in her home.

DISCUSSION

Summaiy judgment shall be granted where there are no genuine issues as to any material fact and where the moving parly is entitled to judgment as a matter of law. Mass.R.Civ.P. 56(c); Cassesso v. Comm’r of Corr., 390 Mass. 419, 422 (1983); Cmty. Natl Bank v. Dawes, 369 Mass. 550, 553 (1976). The existence of disputed facts is consequential only if those facts have a material bearing on the disposition of the case. Norwood v. Adams Russell Co., 401 Mass. 677, 683 (1988). The moving parly bears the burden of affirmatively demonstrating the absence of a triable issue, and that the summaiy judgment record entitles him to judgment as a matter of law. Pederson v. Time, Inc., 404 Mass. 14, 16-17 (1989). The moving party may satisfy this burden either by submitting affirmative evidence that negates an essential element of the opposing party’s case or by demonstrating that the opposing party has no reasonable expectation of proving an essential element of his case at trial. Flesner v. Technical Communications Corp., 410 Mass. 805, 809 (1991); Kourouvacilis v. Gen. Motors Corp., 410 Mass. 706, 716 (1991).

I. Negligence Claim

Regarding common-law negligence, the defendant relies upon the line of cases represented by Andrade v. Baptiste, 411 Mass. 560 (1992), in which the court held that a woman could not be found to owe a duty to a bystander from the ownership and use of a firearm by her husband who also had a histoiy of alcohol abuse. Among other firearms cases relied upon by the defendant and the Andrade court are Sabatinelli v. Butler, 363 Mass. 565 (1973), and McDonald v. Lavery, 27 Mass.App.Ct. 1108 (1989). The plaintiff seeks to distinguish these cases from the case at bar with the point that in each of the decided cases, the defendant was an immediate family member of the gun owner and shooter, and thus without any recourse to prohibit or control conduct, whereas here, the defendant was not married to or otherwise related to the owner of the weapon and, therefore, with a right to prohibit the introduction of weapons into her house or to insist upon greater security, enforceable by revoking a license to occupy her home.

[618]*618Notwithstanding this distinction, the situation presented herein is analogous to the cases involving the denial of claims of duty owed by social hosts, simply by reason of ownership and control over the premises, in connection with: injuries sustained by fireworks brought to their home by guests that injure other guests (see Luoni v. Berube, 431 Mass. 729 (2000), Flanagan v. Baker, 35 Mass.App.Ct. 444 (1993)), a guest’s excessive use of alcohol that is neither served nor made available by the homeowner that causes injury to third parties, including other guests and passersby (see Ulwick v. DeChristopher, 411 Mass. 401 (1991), Wallace v. Wilson, 411 Mass. 8 (1991)), or “the criminal acts of a social guest that cause injury to a third party in the absence of events that would lead a reasonable host to anticipate danger.” Anthony H. v. John G., 415 Mass. 196, 200 (1993); Pollard v. Powers, 50 Mass.App.Ct. 515, 518 (2000); Husband v. Dubose, 26 Mass.App.Ct. 667, 670 (1988).

Nor is this case sufficiently analogous to Sojka v. Dlugosz, 293 Mass. 419 (1936), a case relied upon by the plaintiff to provide support. There, the owner of the gun left it unsecured and easily obtainable where it was taken by his son who injured the plaintiff when he accidently fired it — factors not present in this case.

With respect to the statute upon which the plaintiff relies, G.L.c. 140, §131L, the plaintiff contends that an alleged violation of such a safety statute by the defendant homeowner is evidence of negligence sufficient to withstand a motion under Mass.R.Civ.P. 56. The defendant contends, and this court agrees, that its requirements for any firearm to be equipped with a trigger lock or kept in a securely locked container apply only to the licensed owner of the firearm, as the statute is a part of a specific licensing statute with respect to the purchase, sale, ownership and carrying of firearms, i.e., G.L.c. 140, §§121-31P, which includes criminal penalties for violations thereof. Moreover, as a part of the duties upon licensed gun dealers, the law imposes an express duty imposed upon a licensed dealer to post in a conspicuous location in the retail premises the statutory obligations of secure storage. G.L.c. 140, § 123. A person who neither purchased the weapon nor owns it would not come into contact with this notice. Implicit in such a directive is that the person who purchases the firearm is the intended beneficiary of the warning and upon whom the duty to secure safely rests.

For the foregoing reasons, the defendant’s motion for summary judgment as to the plaintiffs negligence claim is allowed.

II. Strict Liability Claim

In connection with the plaintiffs argument for imposition of strict liability under Rylands v. Fletcher (L.R. 3 H.L. 330 (1868)), for an ultra-hazardous activity, the analogy that appears closest to the facts in question is the line of blasting cases.

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Related

Sabatinelli v. Butler
296 N.E.2d 190 (Massachusetts Supreme Judicial Court, 1973)
Connerty v. Metropolitan District Commission
495 N.E.2d 840 (Massachusetts Supreme Judicial Court, 1986)
Flanagan v. Baker
621 N.E.2d 1190 (Massachusetts Appeals Court, 1993)
Pederson v. Time, Inc.
532 N.E.2d 1211 (Massachusetts Supreme Judicial Court, 1989)
Stop & Shop Companies, Inc. v. Fisher
444 N.E.2d 368 (Massachusetts Supreme Judicial Court, 1983)
Town of Norwood v. Adams-Russell Co.
519 N.E.2d 253 (Massachusetts Supreme Judicial Court, 1988)
Community National Bank v. Dawes
340 N.E.2d 877 (Massachusetts Supreme Judicial Court, 1976)
Husband v. Dubose
531 N.E.2d 600 (Massachusetts Appeals Court, 1988)
Kourouvacilis v. General Motors Corp.
575 N.E.2d 734 (Massachusetts Supreme Judicial Court, 1991)
Flesner v. Technical Communications Corp.
575 N.E.2d 1107 (Massachusetts Supreme Judicial Court, 1991)
Wallace v. Wilson
575 N.E.2d 1134 (Massachusetts Supreme Judicial Court, 1991)
Cassesso v. Commissioner of Correction
456 N.E.2d 1123 (Massachusetts Supreme Judicial Court, 1983)
The Clark-Aiken Co. v. Cromwell-Wright Co. Inc.
323 N.E.2d 876 (Massachusetts Supreme Judicial Court, 1975)
Anthony H. v. John G.
612 N.E.2d 663 (Massachusetts Supreme Judicial Court, 1993)
Andrade v. Baptiste
583 N.E.2d 837 (Massachusetts Supreme Judicial Court, 1992)
Ulwick v. DeChristopher
582 N.E.2d 954 (Massachusetts Supreme Judicial Court, 1991)
Kaufman v. Boston Dye House, Inc.
182 N.E. 297 (Massachusetts Supreme Judicial Court, 1932)
Sojka v. Dlugosz
200 N.E. 554 (Massachusetts Supreme Judicial Court, 1936)
Cohen v. Brockton Savings Bank
71 N.E.2d 109 (Massachusetts Supreme Judicial Court, 1947)
O'Connor v. E. J. DiCarlo & Sons, Inc.
378 N.E.2d 695 (Massachusetts Supreme Judicial Court, 1978)

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17 Mass. L. Rptr. 617, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jupin-v-kask-masssuperct-2004.