Court holds that parents cannot sue owners of home for death of drunken minor who committed suicide
The Court of Appeals upheld the dismissal of Rita Costigian v. Kevin Plets and Cindy Plets. The Plaintiff, Rita, was the mother of Jonathon Costigian and the Personal Representative of his Estate. She sued the defendants after Jonathan hung himself in the Plets' basement. Jonathan and the Plets' son had previously consumed alcohol at the Plets' home, apparently, and when the Plets left the house on an evening in May of 2008, a minor drinking party ensued. When the Plets got home, they kicked some kids out, called parents to let them know what happened, and left the drunken kids to "sleep it off." In the morning, they discovered Jonathan a suicide in the basement. His parents sued, arguing that they were negligent in allowing the party to occur and in failing to anticipate Jonathon's suicide.
The Court upheld the dismissal of the Costigian Estate's claim. It held, essentially, that the Plets did not have enough knowledge of the likelihood of an illegal party to make them negligent in allowing it to occur. The Court held, in fact, that the Costigians did not present enough evidence to raise even a question of fact on this topic. The Court also held that the Plets would not be responsible in any event, because Jonathon's suicide was a "subsequent intervening event" that eliminated any argument that the Defendants' negligent behavior had "caused" his death.