Chapman v. Mayfield

In order to show violence resulted from an establishment negligently serving alcohol to a visibly intoxicated person, a plaintiff must show that the violent act was a reasonably foreseeable result of service though sufficient evidence.

Chapman sued the Eagles Lodge (the Lodge), asserting they negligently served Mayfield while he was visibly intoxicated, leading to Mayfield later shooting Chapman. The trial court granted the Lodge’s motion for summary judgment on the grounds that Chapman had not presented sufficient evidence to show a factual dispute as to whether the shooting was a foreseeable consequence of the Lodge serving Mayfield. On appeal, Chapman argued those who are in the business of serving alcohol know that serving a visibly intoxicated person may lead to violence. The Court rejected this argument, finding that the Lodge was not on notice that Mayfield would become violent purely by virtue of being a business that serves alcohol. The Court held it could not be rationally inferred by the Lodge that there was an unreasonable risk of violence by serving Mayfield based on the facts of this case. Because there was insufficient evidence to support such an inference, the trial court was not in error in granting the Lodge’s motion. Affirmed.