Sheila Renee White MAYO, Individually and as Administratixof her Minor Children, Rina Mayo, Jaclyn Mayo andPaige Mayo, Plaintiffs-Appellants,v.HYATT CORPORATION, Defendant-Appellee.
No. 89-3576Summary Calendar.
Background Information
The case was a collective petition from Sheila Renee Mayo along with her three minor children. It was an appeal case based on the district court’s summary dismissal of their case on grounds of insufficient evidence to support the claim. The claimants had sued the Hyatt Corporation, through Hyatt for the death of Jack Mayo the husband and father of the petitioners consecutively. The district courts found the deceased 100 per cent contributory negligent and responsible for his plight. The court noted that the Louisiana law placed the liability for the consequences of intoxication on the culprit. Furthermore, it expressly disclaims what calls ‘dramshop’ liability. The existing precedents such Thrasher v. Leggett, defined liability on proof of the commission of an affirmative action with potency to increase the risk of an intoxicated person. The courts applied this standard to determine the duty of care in the context of innkeeper-guest relationship as noted in the case of Gregory v Constitution State. Before this decision, courts held that a person was wholly responsible for any injury from volitional intoxication. Furthermore, the legal consensus was that there was no higher duty for innkeepers than refraining from contributory affirmative acts.
Top Four Facts of the Case
Fact: One
Just a few minutes before the midnight of the 17th day of February 1987, Jackson Mayo fell several steps in the Hyatt hotel in New Orleans sustaining serious injuries. This fact was uncontested in both courts, the district and the appeal. Heitzmann’s testimony was an affirmation of the same. He was on duty on the alleged day and was the sole witness to the events as they unveiled. This was an uncontended fact, though.
Fact: Two
Mayo sustained serious bodily harm from the fall. His skull broke from the accident. He died three days after the accident. The attending doctors contributed to some extent to the resulting death. According to the law of causation, the link between the injury and the death did suffice to attach liability (Steel 21). However, proving that death was the major cause of the death was not enough as the onus to prove a duty of care was squarely on the plaintiff. In light of the circumstances of this case, whether or not the injury was the cause of death was a non-issue and uncontended.
Fact: Three
The deceased was intoxicated during the time of the accident. Blood tests after the accident confirmed that the alcohol level was three times beyond the legal limit. Further tests indicated that he had ingested significant quantities of cocaine. Arguably, these had impaired his capacity to take care of himself.
Fact: Four
The stairs of the premises did not have any structural defect that could have predisposed the deceased in the accident. They were well carpeted throughout, with handrails on either side for protection. Further, they did not have any physical defects, and neither were there any foreign objects present at the time of the accident. The structure was in place for a long time since its installation, and there were no prior reported similar incidences. As such, the premise could not have been said to be in the habit of occasioning users to such incidences. The plaintiffs did not allege that the stairs exhibited any structural defects either, or the defendant maintenance of the structure was improper and contributory. Under these circumstances, the district court asserted that the plaintiff did not owe the deceased any duty of care and consequently could not grant the relief sought. The plaintiffs filed their appeal under these circumstances seeking reversal of the lower court decision, and a possibly get relief.
Issue of the Court of Appeal
Was the district court decision that the defendant’s duty of care under the Louisiana law was limited to refraining from affirmative actions that rocket the deceased peril of the consequences of self-intoxication justified? The district court had dismissed the plaintiffs’ decisions summarily for want of sufficient evidence to sustain their claim. The law in usage did not require innkeepers to observe a higher duty to their guests other than avoiding affirmative actions that served to increase the risks attached. The conditions of the house could have been a further consideration to attach liability, but the petitioners had not made an allegation to that direction. The effect of the decision was to adjudge the deceased as 100 percent liable for his fate and consequently deny the plaintiffs any avenue for relief.
Decision
The court affirmed the district court’s decision dismissing the claimant's case on the grounds that the defendants did not have a higher duty than that prescribed by law, to protect the deceased from the consequences of his voluntary intoxication.
Reasoning:
Plaintiff Evidence
The claimants’ case was premised on the position that the defendant had a higher duty to the deceased to protect him from self- inflicted woes. The Louisiana law defined the guest innkeepers duty in two ways. First, the duty to maintain a risk-free environment. The court reasoned that this risk did not obligate the defendant to maintain an ‘inebriated risk proof’ environment. The court observed that the duty defined by the law is a standard one and not a strict nor higher than is reasonable. Under this category, it suffices to maintain conditions that do not expose guests to unnecessary risks. Secondly, the law requires an innkeeper to refrain from affirmative actions that inevitably increase dangers of a self-inflicted risk of intoxication. The requirement of affirmative action needs one to prove a positive act. Inaction and impassive acts may not fit the definition of an affirmative action. The court observed that the plaintiffs failed to prove an affirmative act that increased the self-inflicted risks of the deceased. The petitioners relied heavily on the expert evidence that Heitzmann, the gourd on duty lacked the necessary training. Their argument was that a properly trained guard would have taken further measures, including cajoling and the use of force to prevent the deceased from taking the stairs where he injured himself. In light of Louisiana law, the court observed that whether or not that answered in the affirmative, it was immaterial in attaching liability.
Court’s Evidence
The court observed that the duty of care of the defendants was in two categories, refraining from affirmative actives that could have increased the risk of the defendants and maintaining the premises in reasonably safe conditions. The court observed that the defendant did not allege the premises had flaws of any nature that contributed to the injury of the deceased. It also reasoned that plaintiffs failed to prove that the defendant engaged in any affirmative act that increased the risk thereof. It further noted that these were essential elements of the case. Citing the case of Celotex Corp. v. Catrett, the presiding judges, concluded that failure to prove these elements rendered all other facts of the case materials (Gordillo 7). With these facts, it concluded that the district court had not erred in allowing the motion for summary judgment that led to the dismissal. The appeal court has so adjudged the appeal.
Works Cited
Gordillo, Gregory A. "Summary Judgment and Problems in Applying the Celotex
Trilogy Standard." Clev. St. L. Rev. 42 (1994): 263.
Steel, Sandy. Proof of Causation in Tort Law. Vol. 120. Cambridge University Press, 2015.
