Rowland v. Christian, 70 Cal. Rptr. 97, 69 Cal. 2d 108, 443 P. 2d 561 (1968)
FACTS: Christian invited Rowland into her apartment. While using Christian’s bathroom, Rowland’s tendons and nerves on his right hand were severed. He went to the hospital and incurred medical expenses.
ISSUE: Whether Rowland (Plaintiff) can sue Christian (Defendant) for damages for her failure to warn him of the dangerous bathroom fixtures.
RULE: Negligence requires a showing that defendant owed a duty of care to plaintiff, defendant breached duty of care, plaintiff was injured, and defendant’s negligence resulted in plaintiff’s injuries. Furthermore, every person is responsible…for an injury induced to another by their lack of ordinary care…in the management of their property…unless a person has brough an injury upon themself.
ANALYSIS: The Court found Defendant was aware of the conditions in her bathroom. Defendant knew those conditions were unsafe, and were liable to cause harm to others who come in contact with it. Defendant also knew if a person did come in contact with it, they would likely be injured. Given these points, the Court concluded the Defendant failed to warn Plaintiff of its conditions. The Court based its finding on Section 1714 of the Civil Code, which states, “every person is responsible…for an injury induced to another by their lack of ordinary care…in the management of their property…unless persons brings an injury upon themselves.”
CONCLUSION: Because the Defendant foresaw the harms of allowing individuals into her bathroom, and failed to warn Plaintiff that the conditions in the bathroom was unsafe, the Defendant is liable for damages. Reversed.
