Halvorson exception in Washington

8 Washington opinions name it 2 courts 1979–2004 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

Case	Followed	Cited
Halligan v. Pupogreen washctapp · 1984 · cited in 2 Washington opinions naming this issue, 1984–1990 2 sentences 1984The Halvorson exception has been expanded from one in such a state of helplessness or debauchery as to be deprived of his willpower to one "obviously intoxicated." Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982); Young v. Caravan Corp., 99 Wn.2d 655, 658 , 663 P.2d 834 (1983); Halligan v. Pupo, 37 Wn. 1984The Halvorson exception has been expanded from one in such a state of helplessness or debauchery as to be deprived of his willpower to one "obviously intoxicated." Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982); Young v. Caravan Corp., 99 Wn.2d 655, 658 , 663 P.2d 834 (1983); Halligan v. Pupo, 37 Wn.	1	2
Ueland v. Pengo Hydra-Pull Corp.green wash · 1984 · cited in 1 Washington opinions naming this issue, 1986–1986 2 sentences 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan	1	1
Petersen v. Stategreen wash · 1983 · cited in 1 Washington opinions naming this issue, 1986–1986 2 sentences 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan	1	1
Callan v. O'NEILgreen washctapp · 1978 · cited in 1 Washington opinions naming this issue, 1982–1982 2 sentences 1982See Callan v. O'Neil, 20 Wn. 1982See Callan v. O'Neil, 20 Wn.	1	1
Stranger v. New York State Electric & Gas Corp.green nyappdiv · 1966 · cited in 1 Washington opinions naming this issue, 1979–1979 2 sentences 1979See Stranger v. New York 232 State Elec. & Gas Corp., 25 App. Div. 2d 169, 268 N.Y.S.2d 214 (1966); Motyka v. Amsterdam, 15 N.Y.2d 134 , 204 N.E.2d 635 , 256 N.Y.S.2d 595 (1965). 1979See Stranger v. New York 232 State Elec. & Gas Corp., 25 App. Div. 2d 169, 268 N.Y.S.2d 214 (1966); Motyka v. Amsterdam, 15 N.Y.2d 134 , 204 N.E.2d 635 , 256 N.Y.S.2d 595 (1965).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (5)

Case	Cited	Years
Wilson v. Steinbach green wash · 1982 2 sentences 2004We subsequently applied the Halvorson rule 13 years later, stating, “hi Halvorson, we recognized and adopted the general common law rule of nonliability for furnishing intoxicants to an able-bodied person, while simultaneously recognizing the exceptions to the rule for obviously intoxicated persons, persons in a state of helplessness, or persons in a special relationship to the furnisher of intoxicants.” Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982) (emphasis added) (citing Halvorson, 76 Wn.2d at 762-63 ). 2004We subsequently applied the Halvorson rule 13 years later, stating, “hi Halvorson, we recognized and adopted the general common law rule of nonliability for furnishing intoxicants to an able-bodied person, while simultaneously recognizing the exceptions to the rule for obviously intoxicated persons, persons in a state of helplessness, or persons in a special relationship to the furnisher of intoxicants.” Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982) (emphasis added) (citing Halvorson, 76 Wn.2d at 762-63 ).	5	1984–2004
Halvorson v. Birchfield Boiler, Inc. green wash · 1969 2 sentences 2004We subsequently applied the Halvorson rule 13 years later, stating, “hi Halvorson, we recognized and adopted the general common law rule of nonliability for furnishing intoxicants to an able-bodied person, while simultaneously recognizing the exceptions to the rule for obviously intoxicated persons, persons in a state of helplessness, or persons in a special relationship to the furnisher of intoxicants.” Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982) (emphasis added) (citing Halvorson, 76 Wn.2d at 762-63 ). 2004We subsequently applied the Halvorson rule 13 years later, stating, “hi Halvorson, we recognized and adopted the general common law rule of nonliability for furnishing intoxicants to an able-bodied person, while simultaneously recognizing the exceptions to the rule for obviously intoxicated persons, persons in a state of helplessness, or persons in a special relationship to the furnisher of intoxicants.” Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982) (emphasis added) (citing Halvorson, 76 Wn.2d at 762-63 ).	2	2004–2004
Young v. Caravan Corporation red wash · 1983 2 sentences 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan 1986Hence, this court is giving specific content to the Halvorson exception that would allow the attachment of liability on the basis of a "special relationship", Young v. Caravan Corp., 99 Wn.2d at 658 (quoting Wilson v. Steinbach, 98 Wn.2d 434, 438 , 656 P.2d 1030 (1982)); see also Petersen v. State, 100 Wn.2d 421, 422 , 671 P.2d 230 (1983) combined with a finding of "obvious drunkenness." 4 Even if this recognition of liability were not the logical extension of principles we have announced in earlier deci sions, we would be abdicating our duty to "reform the common law to meet the evolving stan	2	1984–1986
Wiener v. Gamma Phi Chapter of Alpha Tau Omega Fraternity green or · 1971 2 sentences 1982In favor of this proposition, petitioners cite Wiener v. Gamma Phi Chapter of Alpha Tau Omega Fraternity, 441 258 Or. 632 , 485 P.2d 18 (1971). 1982In favor of this proposition, petitioners cite Wiener v. Gamma Phi Chapter of Alpha Tau Omega Fraternity, 441 258 Or. 632 , 485 P.2d 18 (1971).	1	1982–1982
Motyka v. City of Amsterdam green ny · 1965 2 sentences 1979See Stranger v. New York 232 State Elec. & Gas Corp., 25 App. Div. 2d 169, 268 N.Y.S.2d 214 (1966); Motyka v. Amsterdam, 15 N.Y.2d 134 , 204 N.E.2d 635 , 256 N.Y.S.2d 595 (1965). 1979See Stranger v. New York 232 State Elec. & Gas Corp., 25 App. Div. 2d 169, 268 N.Y.S.2d 214 (1966); Motyka v. Amsterdam, 15 N.Y.2d 134 , 204 N.E.2d 635 , 256 N.Y.S.2d 595 (1965).	1	1979–1979

Statutes the citing opinions construe

WA § Wash. Rev. Code § 66.44.270 (5) WA § Wash. Rev. Code § 66.44.200 (4) WA § Wash. Rev. Code § 5.40.050 (3) WA § Wash. Rev. Code § 66.08.010 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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