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Copyright (c) 1992 University of Hawai'i Law Review
University of Hawai'i Law Review

Johnston v. KFC National Management Co.: Employer Social-Host Liability for Torts of Intoxicated Employees

Fall, 1992

14 Hawaii L. Rev. 829


Darcie S. Yoshinaga *


I. Introduction

Over the years, the Hawaii State Legislature "has demonstrated an active and ongoing interest in enacting heavier punishment for alcohol abusers and drunk drivers." 1 Indeed, society has become increasingly aware of the dangers of mixing gasoline and liquor. 2 Furthermore, the catastrophic personal and economic impacts incident to accidents resulting from drinking and driving "are a profoundly disturbing social phenomena of our time." 3

While the intoxicated driver generally bears the responsibility for injuries caused in alcohol-related vehicular accidents, society has at tempted to impose blame on the driver's liquor furnisher(s) as well. 4 Today, "social host liability remains a controversial tool for reducing the incidence of drunk driving." 5

Johnston v. KFC Nat'l Management Co. 6 is the most recent Hawaii case dealing with the issue of social host liability. In Johnston, the Hawaii Supreme Court held that social hosts owed no duty of care to protect a third party against risks of injury caused by an intoxicated guest. 7

This casenote addresses the issue of social host liability where the social host is the employer of the intoxicated driver, and discusses various theories of social host liability. It concludes with a discussion of the impact of the Johnston holding on future litigants.

II. Facts

On December 19, 1986, the employees of the Aiea branch of KFC (formerly Kentucky Fried Chicken) planned an after-hours Christmas party for themselves. 8 KFC management gave approval for the party to be held on the ...
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