Maher v. Voss

84 A.2d 527, 46 Del. 418, 1951 Del. Super. LEXIS 122
CourtSuperior Court of Delaware
DecidedAugust 10, 1951
Docket996, 997, Civil Action 1950
StatusPublished
Cited by17 cases

This text of 84 A.2d 527 (Maher v. Voss) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maher v. Voss, 84 A.2d 527, 46 Del. 418, 1951 Del. Super. LEXIS 122 (Del. Ct. App. 1951).

Opinion

*420 Carey, Judge:

Two questions are presented: (1) was Mrs. Maher’s status that of an invitee or licensee; (2) does the complaint show any actionable negligence? The present motion may, of course, be granted only if it appears to a certainty that the plaintiffs would not be entitled to relief under any state of facts which could be proved in support of the claim. Berghane v. Radio Corporation of America, (D. C.) 4 F. R. D. 446; 2 Moore’s Fed. Practice (2d. ed.) 2245.

No Delaware case has been brought to my attention wherein our Court has undertaken to define, in general terms, the distinction between invitees and licensees. In Reardon v. Exchange Furniture Store, 7 W. W. Harr. 332, 188 A. 704, the Supreme Court held that a plumber, engaged to remove a broken hopper and install a new one in a store, was not acting within the *421 scope of Ms invitation when he took the old hopper Mto the cellar without the consent or knowledge of the property owner. His status as an invitee ceased and became that of a licensee or trespasser.

Plaintiffs suggest that the Court should adopt the categories and defimtions set forth in Chapter 13, Restatement, Torts, Negligence. The authors of that work, recognizing the confusion of language which has arisen in the various opinions, have used the terms “business visitor” and “gratuitous licensee” to describe what most Courts call “invitee” and “licensee”. For all practical purposes of this case, it is unnecessary to choose the name to be used. Under my view, Mrs. Maher was a licensee rather than an invitee, m the language of most Courts, or she was a gratuitous licensee rather than a business visitor, in the language of the Restatement. It is not suggested that any business or financial relationship existed. The nature of the functions and activities of the “Democratic Women of New Castle County” is not explained. From its name, I take it to consist of certain women in that County who are mterested m promotmg the objects and principles of the Democratic Party. It is not averred. that either Mrs. Maher or Mrs. Voss had any other or greater interest in the meeting than this, or even that either of them had any hope or expectation of personal benefit from the Democratic Party. Moreover, it is not charged that the defendants received, or expected to receive, any consideration for the use of their home by the group.

The facts compel the conclusion that Mrs. Maher was simply a social guest. As such, by the great weight of authority, she was a licensee or gratuitous licensee, whichever term is preferred. Restatement, Negligence, 897; Cosgrave v. Malstrom, 127 N. J. L. 505, 23 A. 2d 288; Biggs v. Bear, 320 Ill. App. 597, 51 N. E. 2d 799, 92 A. L. R. 1002; Lewis v. Dear, 120 N. J. L. 244; 198 A. 887; Comeau v. Comeau, 285 Mass. 578, 189 N. E. 588; Greenfield v. Miller, 173 Wis. 184, 180 N. W. 834, 12 A. L. R. *422 982; Goldberg v. Straus, Fla., 45 So. 2d 883; Southcote v. Stanley, 1 H & N. 247, 156 Eng. Reprint 1195; 38 Am. Jur. 778.

The only cases cited by plaintiffs on this point do not in fact conflict with this holding. They are the Vermont cases of Wool v. Lamer, 112 Vt. 431, 26 A. 2d 89 and Manley v. Haus, 113 Vt. 217, 32 A. 2d 668. In both of them the definitions of the Restatement are accepted and adopted. As indicated above, that authority expressly places social guests in the category of gratuitous licensees. Moreover, the facts of the two cited cases materially differ from those of the present one. In the Wool case, the plaintiff was the guest of the tenant of an apartment in a building owned by the defendants and was injured in a driveway. The driveway was under the control of the defendants, but was used by all tenants. As to the defendants the plaintiff was held to he a business visitor. The Court gave no consideration to the relationship which exists between social guest and his host. Even less in point is the Manley case, where the plaintiff, wife of a radio repairman, went into defendant’s garage with her husband to help him remove a radio which defendant had engaged him to get and repair. The wife was injured in the garage. She was held to be a business visitor.

In view of Mrs. Maher’s status as a licensee, does the complaint charge any actionable negligence on the part of the defendants? Reardon v. Exchange Furniture Store, supra, is not very helpful in answering this question. It does state that the only duty that defendant owed to the plaintiff was to see that he was not injured by reason of wanton, willful or other active negligence on the part of the defendant. Just what is meant by “active negligence” is not entirely clear. Neither the trial Court nor the Supreme Court stated what Reardon’s status became when he started down the cellar steps. It is, therefore, impossible to say whether the standard of care therein laid down is intended to apply only to trespassers or to licensees as well. Moreover, the Court had before it no problem of a trap or hidden danger since Reardon’s fall was caused by some foreign *423 matter on a step. Likewise, the Court was not concerned with any failure to warn Reardon of a danger known to defendant, since the defendant had no reason to anticipate that Reardon would take the old hopper into the cellar. Clearly, the owner violated no duty it owed to him under the circumstances, whether he was trespasser or licensee, and the opinions of both Courts were naturally limited to a discussion of the problems presented by the circumstances.

A review of counsels’ citations and of numerous other authorities demonstrates some apparent conflict in the decisions of other jurisdictions concerning the duty of a property owner towards a licensee. What may be called foreseeability of risk has no doubt played an important part in the result reached in most cases. The rules which probably meet widest approval are those summarized in the Restatement. No liability rests upon a possessor of land, even to a business visitor, for bodily injury caused by a dangerous condition on the land, if the visitor knows of the condition and realizes the risk involved.

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Bluebook (online)
84 A.2d 527, 46 Del. 418, 1951 Del. Super. LEXIS 122, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maher-v-voss-delsuperct-1951.