Rowland v. Christian (1968)

IRAC Summary:

Issue: The issue in Rowland v. Christian is whether a possessor of land is liable to a non-social guest for injuries caused by a defective condition on the premises.

Rule: The court abolished the traditional distinctions between invitees, licensees, and trespassers in determining the duty of care owed by a possessor of land. The court held that a uniform duty of reasonable care under all the circumstances should be applied.

Application: The plaintiff, Rowland, was injured by a defective faucet in the defendant’s, Christian’s, apartment. Christian was aware of the defect but failed to warn Rowland or to repair it. The court applied the newly established rule of reasonable care to determine if Christian breached her duty towards Rowland by considering factors such as the foreseeability of harm, the degree of certainty that Rowland would suffer injury, the closeness of the connection between Christian’s conduct and the injury suffered, the moral blame attached to Christian’s conduct, and the policy of preventing future harm.

Conclusion: The court concluded that Christian had a duty to exercise reasonable care to Rowland, which included a duty to warn or make the condition safe. The failure to fulfill this duty was a breach that resulted in Rowland’s injuries, thus establishing liability.

Detailed IRAC Outline:


The precise issue here is whether the defendant, Terry Christian, owed the plaintiff, Lowell Rowland, a duty of reasonable care to warn about or repair a defective condition (a broken faucet) in her apartment that ultimately caused injury to Rowland.


The court focused on the following rules:
1. Traditional common law categorized individuals on another’s property as invitees, licensees, or trespassers, each owed a different level of duty by the property possessor.
2. The court recognized that maintaining these distinctions is unjust and that a general duty of care should be uniformly applied.
3. The general duty of care, as established by the court, requires that all possessors of land must act as a reasonable person under similar circumstances, taking into account factors such as the foreseeable risk of harm.


In applying the rule to the facts of the case:
1. Rowland was a guest in Christian’s apartment, thus under traditional rules, would be considered a licensee.
2. Christian knew about the broken faucet, which created a foreseeable risk of harm to anyone using it.
3. The traditional classification would not have required Christian to repair the defect or warn Rowland about it, as he was not an invitee.
4. The court applied the new rule of reasonable care, finding that Christian’s knowledge of the defect and the reasonable foreseeability of injury from the defect imposed a duty to warn or repair.
5. The court considered the likelihood and severity of potential harm, the burden on Christian to warn or repair, and the desirability of placing that burden on her.
6. Christian’s actions (or inactions) were closely connected to Rowland’s injury, and there was moral blame attached to not warning about a known danger.
7. Preventing future harm also supported imposing a duty of care, as it encourages possessors to maintain safe conditions.


Concluding the application of the rule to the facts, the court held that Christian breached her duty of care owed to Rowland by failing to warn him of the defective faucet or to repair it. As this breach was the proximate cause of Rowland’s injuries, Christian was found liable for the damages suffered by Rowland. The case thus established that all possessors of land owe a uniform duty of reasonable care to all persons on their premises, regardless of the traditional classification of such persons.

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