Lucas v. C & B Associates

18 Va. Cir. 446, 1990 Va. Cir. LEXIS 12
CourtRoanoke County Circuit Court
DecidedJanuary 31, 1990
DocketCase No. CL 89-899
StatusPublished

This text of 18 Va. Cir. 446 (Lucas v. C & B Associates) is published on Counsel Stack Legal Research, covering Roanoke County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lucas v. C & B Associates, 18 Va. Cir. 446, 1990 Va. Cir. LEXIS 12 (Va. Super. Ct. 1990).

Opinion

By JUDGE DIANE McQ. STRICKLAND

In addressing this issue [raised by the demurer of C & B Associates], all facts alleged in or reasonably inferable from the motion of judgment are considered true. West Alexandria Properties, Inc. v. First Virginia Mortgage and Real Estate Investment Trust, 221 Va. 134, 267 S.E.2d 149 (1980). The following facts are controlling.

On the night of July 25-26, 1989, Kelly was a patron and customer of a lounge known as "The Elephant Walk", operated under the management, supervision and control of defendant C & B Associates. Kelly purchased and consumed alcoholic beverages on the premises of The Elephant Walk which resulted in his severe intoxication, a fact apparent to common observation. At approximately 1:30 a.m. on July 26, 1989, when Kelly indicated his intention to depart The Elephant Walk, one of his friends, noting that he was in no condition to drive at that time, took the keys [447]*447to Kelly’s pick-up truck and informed him that she would call a taxi cab. The friend in turn gave these keys to defendant Russell, who was employed by C & B Associates as a security guard or bouncer for The Elephant Walk, with the admonition to withhold the keys from Kelly while she called the cab.

Russell, noting Kelly’s inebriated state and agreeing that he could not drive safely, accepted custody of the keys. A few minutes later, however, Russell relinquished the keys to Kelly, knowing that Kelly intended to drive his truck home but was too intoxicated to do so safely. Kelly proceeded to drive his truck from The Elephant Walk and thereafter struck plaintiff’s decedent who was standing on the running board of a tow truck which had been called to the scene of another accident.

C & B Associates demurred to plaintiff’s motion for judgment on the ground the "Virginia does not recognize a cause of action against a restaurant or its employees for failing to stop an intoxicated patron from leaving the premises." Pursuant to Virginia Code § 8.01-273 (1950 as amended) this Court will consider only that ground in determining whether plaintiff’s motion for judgment has failed to state a cause of action upon which relief can be granted against C & B Associates.

The law in Virginia is clear that liability is not imposed upon an establishment that serves alcohol to a patron who subsequently drives an automobile and injures a third party. The General Assembly of Virginia has not enacted "dram shop" legislation which would impose such civil liability and no such liability is grounded in the common law. The Virginia Supreme Court addressed this issue of "nonliability" extensively in the case of Williamson v. The Old Brogue, Inc., 232 Va. 350, 353, 350 S.E.2d 621 (1986). Williamson was injured in an automobile accident with Loredo who had become intoxicated as a result of consumption of alcoholic beverages at The Old Brogue. The trial court sustained the defendant’s demurrer and the Supreme Court affirmed holding "nonliability of one furnishing intoxicants under these circumstances is a part of the common law in Virginia." 232 Va. at 353.

The Court rejected Williamson’s arguments that a violation of Virginia Code § 4-62(l)(c) by the defendant constituted actionable negligence or made the defendant [448]*448negligent per se stating "the Act mandates no statutory tort liability." 232 Va. at 355. The theory that the negligence of The Old Brogue was akin to negligent entrustment, imposing liability on an owner for knowingly permitting an intoxicated person to drive his vehicle, was also rejected by the Virginia Supreme Court. Accordingly, those questions need not be re-examined by this Court.

The issue before this Court is whether plaintiff’s allegation, that defendant Russell received Kelly’s keys with an admonition not to permit him to drive and thereafter returned the keys to Kelly knowing him to be intoxicated, is sufficient to remove the present case from the scope of Williamson and to withstand the challenge of defendant’s demurrer. Plaintiff contends that C & B Associates played a more significant role than did The Old Brogue, in that C & B’s personnel not only made it possible for Kelly to become intoxicated but also made it possible for him to drive by returning the keys.

C & B responds that Russell simply had no right or duty to withhold Kelly’s keys; and, in fact, it would have been liable under theory of conversion had he elected to do so. In support of this defense C & B cites cases from a number of other jurisdictions holding that a bailee is duty bound to return keys or a vehicle to its lawful owner even knowing such owner to be intoxicated. Knighton v. Sam’s Parking Valet, 206 Cal. App. 3d 69, 253 Cal. Rptr. 365 (1988) (parking valet service not liable to third party struck by intoxicated owner to whom vehicle was returned); Mills v. Continental Parking Corporation, 475 P.2d 673 (1970) (operator of parking lot not liable for returning vehicle to intoxicated owner to subsequently struck a pedestrian); Sampson v. W. F. Enterprises, Inc., 611 S.W.2d 333 (Mo. Ct. App. 1981) (repair shop owner not liable for returning vehicle to intoxicated minor who subsequently killed himself in an accident); Congini v. Portersfield Valve Company, 470 A.2d 515 (1983) (party host with custody of guest’s keys not liable to injured third party for returning keys to guest in an intoxicated state). While the Virginia Supreme Court has not addressed a factually similar situation, the law of conversion in Virginia as defined in Buckeye National Bank v. Huff & Cook, 114 Va. 1, 75 S.E. 561 (1912), exposed defendants [449]*449C & B Associates and Russell to liability for withholding Kelly’s keys when he requested their return.

Plaintiff relies upon the Restatement of Torts sect. 261 for the proposition that Russell was privileged to convert the keys for the purpose of defending a third party against harmful or offensive contact. Even were this section to be adopted as the law of the Commonwealth of Virginia, it creates only a right, not a duty, on the part of Russell to withhold the keys.

Plaintiff contends that C & B, through Russell, breached a duty owed to plaintiff’s decedent, as a member of the general public, by being an accessory before the fact to Kelly’s violation of Virginia Code § 18.2-266, "driving motor vehicle, engine, etc., while intoxicated, etc." An accessory before the fact is one who, sharing the criminal purpose of the perpetrator induces or procures or counsels or commands another to commit the crime, but is absent from its commission. McGhee v. Commonwealth, 221 Va. 422, 270 S.E.2d 729 (1980), Rasnick v. Commonwealth, 4 Va. (2 Va. Cas.) 356 (1823).

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Related

Beale v. Jones
171 S.E.2d 851 (Supreme Court of Virginia, 1970)
McGhee v. Commonwealth
270 S.E.2d 729 (Supreme Court of Virginia, 1980)
Williamson v. the Old Brogue, Inc.
350 S.E.2d 621 (Supreme Court of Virginia, 1986)
Mills v. Continental Parking Corporation
475 P.2d 673 (Nevada Supreme Court, 1970)
Congini by Congini v. PORTERSVILLE ETC.
470 A.2d 515 (Supreme Court of Pennsylvania, 1983)
Sampson v. W. F. Enterprises, Inc.
611 S.W.2d 333 (Missouri Court of Appeals, 1980)
Knighten v. Sam's Parking Valet
206 Cal. App. 3d 69 (California Court of Appeal, 1988)
Scott's Executors v. Trents, Crump, & Bates
4 Va. 356 (Supreme Court of Virginia, 1809)
Buckeye National Bank v. Huff & Cook
75 S.E. 769 (Supreme Court of Virginia, 1912)

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Bluebook (online)
18 Va. Cir. 446, 1990 Va. Cir. LEXIS 12, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lucas-v-c-b-associates-vaccroanokecty-1990.