Marcum v. Bowden

Chief Justice TOAL,

concurring in part, dissenting in part:

I concur in part and respectfully dissent in part. Although I agree with the majority’s adoption of the rule imposing limited social host liability, I would reverse and remand both cases and allow the parties to litigate their disputes under the rule adopted by the Court.

Generally, judicial decisions creating new substantive rights have prospective effect only, whereas decisions creating new remedies to vindicate existing rights are applied retrospectively. Stated otherwise, prospective application is required when liability is created where formerly none existed. Toth v. Square D Co., 298 S.C. 6, 8, 377 S.E.2d 584, 585 (1989) (internal citations omitted). In applying our general rule, this Court and the court of appeals have made decisions “selectively prospective” by applying the rule to the case at bar and to all future cases. Steinke v. South Carolina Dep’t of Labor, *463Licensing, and Regulation, 336 S.C. 373, 400 n. 8, 520 S.E.2d 142, 156 n. 8 (1999) (explaining retroactive and prospective application of decisions); see, e.g., Ludwick v. This Minute of Carolina, Inc., 287 S.C. 219, 225-26, 337 S.E.2d 213, 216 (1985) (holding “[o]ur modification of the termination at will doctrine, as set forth in this opinion, applies only to this case and to those causes of action arising after the filing of this opinion .... ”); and McCormick v. England, 328 S.C. 627, 644, 494 S.E.2d 431, 439 (Ct.App.1997) (recognizing the common law tort of breach of a physician’s duty of confidentiality, and applying decision in this case and prospectively).9

*464In my view, we should extend our decision to impose limited first and third party social host liability to the cases before us today and all future cases which arise after the filing of our opinion. Resolving the eases in this manner would, in my opinion, allow the plaintiffs the benefit of the change in the law which they induced without making our decision retroactive.

The majority declines to extend its ruling to the instant cases because it would “offend notions of fairness ... to retroactively impose tort liability where previously there had been none....” In support of this holding, the majority relies upon the Court’s decision in Russo v. Sutton, 310 S.C. 200, 422 S.E.2d 750 (1992). While the Court did not apply its decision abolishing the tort of alienation of affections in Russo, in my view, Russo is not the exclusive representation of how this Court and others handle cases where a judicial decision prompts a change in the law.10 See supra note 1.

Although I do not think that the imposition of newly created tort liability is appropriate in all cases, in my view, to expect litigants to bear the burdens associated with effecting a needed change in the law without the expectation that they will receive the benefits of the change in the law is more offensive *465to our notions of fairness as well as crippling to our legal system.11 Cf. Aka v. Jefferson Hosp. Assoc., Inc., 344 Ark. 627, 42 S.W.3d 508, 519 (2001) (concluding that “appellant’s efforts to bring about a needed change in the law should not go unrewarded, because without such inducement change might not occur.”) (internal citations omitted).12 Additionally, I believe the majority’s resolution of this case is profoundly impractical and based on hypertechnical analysis of citations that does not adequately provide a rationale for why past litigants have been able to pursue their cases while the litigants in these cases are denied similar relief.

For the foregoing reasons, I would reverse and remand these cases with instructions to retry them in accordance with our recognition of limited first and third party social host liability.

. The majority incorrectly implies that this Court may only permit a party to benefit from the recognition of new tort liability where the imposition of the new tort liability was foreshadowed by previotts decisions. However, assuming foreshadowing is required, I believe our pronouncement of limited first and third party social host liability was adequately foreshadowed by our extension of liability in the commercial context and the statutory laws criminalizing such behavior. See S.C.Code Ann § 61-4-90 (Supp.2005) and § 61-6-4070 (Supp.2005). See also Norton v. Opening Break of Aiken, Inc., 313 S.C. 508, 443 S.E.2d 406 (Ct.App.1994) aff'd 319 S.C. 469, 462 S.E.2d 861 (1995); Whitlaw v. Kroger Co., 306 S.C. 51, 410 S.E.2d 251 (1991).

Additionally, the majority incorrectly assumes that Ludwick and McCormick represent this Court’s entire jurisprudence on the matter. However, this Court has often allowed the parties to an action which prompts a rule change to utilize the new rule. See Davenport v. Cotton Hope Plantation Horizontal Property Regime, 333 S.C. 71, 508 S.E.2d 565 (1998) (holding that the abolition of assumption of risk as an “all or nothing” defense would be applied to the action in which that ruling was made and to all other causes of action that arose or accrued after date of opinion); Kinard v. Augusta Sash & Door Co., 286 S.C. 579, 336 S.E.2d 465 (1985) (recognizing the new cause of action by plaintiff bystander for negligent infliction of emotional distress and applying the new rule to the case); McCall v. Batson, 285 S.C. 243, 329 S.E.2d 741 (1985) (prospectively abolishing sovereign immunity and applying the new rule to the case before the court); Fitzer v. Greater Greenville, S.C. Young Men’s Christian Ass’n, 277 S.C. 1, 282 S.E.2d 230 (1981) (applying the new rule abrogating the doctrine of charitable immunity to the case which prompted the rule change); Elam v. Elam, 275 S.C. 132, 268 S.E.2d 109 (1980) (abolishing the court-created parental immunity doctrine applicable to tort actions brought by unemancipated minors against their parents and applying the new rule to the case at hand and prospectively); Brown v. Anderson County Hosp. Assoc., 268 S.C. 479, 234 S.E.2d 873 (1977) (modifying doctrine of charitable immunity, such that charitable hospitals are liable for heedless and reckless acts, and applying decision in this case and prospectively).

The majority points out that many of the aforementioned cases involve the abolition of an affirmative defense. While I agree that the *464abolition of an affirmative defense does not "create a new duty,” such abolition does impose liability where previously none existed. See McCall, 285 S.C. at 246, 329 S.E.2d at 742 (acknowledging the creation of new tort liability).

. Again, I believe the portion of the majority's rationale which relies on the concept of fairness is misguided. While I understand that fairness is an important consideration, I cannot envision that an extension of potential liability would amount to unfairness in the cases before us today. Arguably, tort liability involves a calculation of risks in evaluating whether to undertake a certain course of action. In the majority's view, extending our ruling to the cases before us today impermissibly adds another variable in the calculus. Stated otherwise, the majority might argue that the potential imposition of civil liability upon the defendants in these cases impermissibly increases their expected accident costs such that it would dramatically change the nature of their decision to serve alcohol at their events. In my view, this critically overstates the case. Although no civil liability existed for social hosts at the time of these incidents, I find it difficult to believe that the defendants were ignorant of any potential liability which could result from serving alcohol to underage drinkers in light of tire existence of criminal statutes prohibiting such behavior and our expanding extension of liability in the commercial context.

. The majority also finds that the plaintiffs have contended only that the defendants were negligent. However, in my opinion, the complaints in these cases actually allege both negligent and willful conduct. Because the plaintiffs' complaints allege an intentional tort, there is no impediment to remanding these cases to allow the parties to proceed under the new rule.

. The majority misapprehends the use of Aka in this dissent. Clearly, from the context and form of the citation, Aka is used to emphasize the rationale under which I find it both practical and just to extend our ruling today to the litigants in these cases, and not in support of the general concept of retroactive/prospective application of rules. However, for further clarification, I use Aka only to support the proposition that litigants should not be expected to bear the burdens associated with effecting a needed change in the law without the expectation that they will receive the benefits of the change in the law. Accordingly, my use of this case does not conflict with South Carolina’s jurisprudence on the retroactive application of statutory changes in the law.