Rowland v. Christian

The plaintiff requested to use the bathroom and a water faucet handle broke off in his hand, leaving him with severed tendons and nerve damage.

Justice Raymond E. Peters wrote the majority opinion, which explained that common law distinctions between an invitee, licensee, and trespasser traditionally determined the duty of care owed by a possessor of land to a plaintiff.

The majority considered the classifications to be an unhelpful shortcut to determine negligence, and that a general duty of care should be owed to all visitors to land.

Reasonable people do not ordinarily vary their conduct depending upon such matters, and to focus upon the status of the injured party as a trespasser, licensee, or invitee in order to determine the question whether the landowner has a duty of care, is contrary to our modern social mores and humanitarian values.

The common law rules obscure rather than illuminate the proper considerations which should govern determination of the question of duty.As of 2000, Rowland had inspired appellate courts in at least nine other U.S. states and the District of Columbia to completely abandon the traditional distinctions between invitees, licensees, and trespassers, while 14 other U.S. states were persuaded by Rowland to modify and simplify those distinctions.