Rowland v. Christian, 69 Cal. 2d 108 (1968), was a case decided by the Supreme Court of California that eliminated the categories of invitee, licensee, and trespasser when determining the duty of care owed by a possessor of land to the people on the land, replacing the classifications with a general duty of care.
The plaintiff was a guest in the apartment of the defendant. The plaintiff requested to use the bathroom, and in the bathroom injured his hand on a broken water faucet handle. The defendant had complained to the landlord about the broken handle but did not warn the plaintiff. The trial judge granted summary judgment on behalf of the defendant, and the plaintiff appealed.
Common law distinctions between an invitee, licensee, and trespasser can determine the duty of care owed by a land possessor to the plaintiff. A duty of care to warn about the dangerous condition of area is owed to invitees and licensees under these distinctions, but not to trespassers. The California Supreme Court considered these classifications to be an unhelpful shortcut when determining negligence, and that a general duty of care should be owed to all visitors to land. The summary judgment for the defendant was reversed because the defendant should have warned the plaintiff of the broken handle.[1]