If you’ve been injured at a holiday party or by someone who attended one, you may have legal rights beyond what you realize. California law holds employers and hosts responsible for injuries that occur not just during parties, but even long after guests have left the event. This is especially true when alcohol is involved.
The landmark Purton v. Marriott (2013) case established that employers can be held liable for injuries occurring hours after their holiday parties end. While these events serve legitimate business purposes by boosting team morale and strengthening workplace relationships, these very benefits create legal obligations under California law.
Holiday party injuries may include slip and falls, alcohol-related vehicle crashes, food-related incidents, parking lot accidents, and more. This guide examines who may bear legal responsibility for these injuries and explains your general rights if you’ve been injured.
Key California Case Law for Company Party Liability
The 2013 case of Purton v. Marriott International, Inc. fundamentally changed how California courts view employer liability for holiday party accidents. This case arose from a tragic incident at the Marriott Del Mar Hotel‘s 2009 holiday party.
The Facts of the Case
Michael Landri, a bartender at the Marriott Del Mar Hotel, attended the hotel’s employee appreciation party in December 2009. Though attendance was voluntary, the hotel hosted the event to thank its employees. Consider these key details:
- Before arriving at the party, Landri had consumed some alcohol
- He brought a flask of bourbon to the party
- A manager who was serving as bartender reportedly refilled Landri’s flask from the hotel’s liquor supply
- After the party, Landri arrived safely at his home but later left to drive a co-worker home.
- During this drive, Landri collided with another vehicle, killing the other driver, Dr. Jared Purton
- Landri later pleaded guilty to gross vehicular manslaughter and received a six-year prison sentence
Dr. Purton’s parents filed a wrongful death lawsuit against Landri, Marriott, and other parties. Initially, the trial court dismissed the case against Marriott, reasoning that Landri wasn’t acting within the scope of his employment when the accident occurred. However, this decision would prove significant when the California Court of Appeal reversed it, establishing new precedent for employer liability.
This case merits careful attention because it sets crucial standards for employer responsibility at holiday parties. The timing of events — particularly the fact that the accident occurred after Landri had already reached home safely — makes this case particularly noteworthy for understanding the extent of employer liability.
Critical Legal Principles Established
The Court of Appeal’s decision established several crucial principles that now guide employer liability in California:
- First, the scope of employment extends beyond the physical boundaries and timeframe of a holiday party. The court rejected the argument that liability ends when an employee leaves the event.
- Second, an employer’s liability doesn’t terminate when an employee reaches home safely. In Purton, Marriott argued this would require employers to escort employees home and keep them there — an argument the court explicitly rejected.
- Third, because employers benefit from holiday parties through improved employee morale and workplace relationships, they bear responsibility for risks created at these events. The court found these benefits place party-related activities within the “scope of employment.”
- Fourth, existing workplace practices significantly impact liability. The court noted that Marriott’s handling of alcohol — including not enforcing its two-drink limit and allowing management to serve alcohol — established a pattern of permissiveness.
The Court’s Key Findings
The Court of Appeal’s decision centered on several critical determinations:
- Employer Benefits Create Liability: The court found that because Marriott benefited from the holiday party by “improving employee morale and furthering employer-employee relations,” it could be held liable for resulting incidents.
- Alcohol Service Creates Ongoing Risk: The court stated plainly that “Marriott created the risk of harm at its party by allowing an employee to consume alcohol to the point of intoxication.” This risk didn’t end when the party did.
- “Safe Arrival” Defense Rejected: The court dismissed Marriott’s argument that liability should end once an employee reaches home safely, noting that the risk created by the employer’s conduct continues as long as the intoxication continues.
- Prevention Requirements: The court outlined several ways Marriott could have reduced risks, including:
- Enforcing its drink ticket policy
- Prohibiting smuggled alcohol
- Limiting alcohol service time
- Serving food
- Completely forbidding alcohol
This decision fundamentally changed how California courts view employer liability for holiday party incidents, extending responsibility well beyond what many employers previously assumed.
Your Rights: When Employers Are Responsible for Holiday Party Accidents
Following the Purton decision, California law recognizes broad employer responsibility for holiday party injuries. Here’s what this generally means for you if you’ve been injured:
When Employers Can Be Held Responsible
You may have a claim against an employer if you were injured:
- At a company holiday party
- After leaving a holiday party
- By someone who attended a company party
- In an accident caused by an intoxicated party attendee
The law doesn’t care whether party attendance was required or voluntary. Even at optional events, employers may be held responsible for injuries.
Why Employers Are Responsible
Courts hold employers responsible because:
- Companies benefit from hosting these events
- Employers can control alcohol service
- Employers can prevent foreseeable risks
- Companies are better positioned to cover injury costs
What This Means for Your Injury Claim
If you’ve been injured, the employer may be responsible for:
- Your medical bills
- Lost wages
- Pain and suffering
- Ongoing care needs
- Other accident-related expenses
This is true even if:
- The party was optional
- You were injured after leaving the event
- You’re not an employee of the company
- The person who injured you had already gone home
Don’t assume you don’t have a case just because the accident happened hours after the party ended. California law recognizes that employer responsibility extends beyond the party itself.
Important Steps After a Company Party Injury
If you’ve been injured at or after a holiday party, taking the right steps can protect your legal rights. Here are a few general items to keep in mind:
Document Everything
Documentation is crucial for your case. Take photos of your injuries and, if possible, the accident scene. Save all communications about the party, including invitations, emails, and texts. While your memory is fresh, write down exactly what happened before, during, and after the incident.
Gather Information
Get the names and contact details of anyone who witnessed the incident. Note who organized the party and who was serving alcohol. If your injury happened at a venue, get the property owner’s information. If a vehicle was involved, exchange insurance information.
Seek Medical Care
Don’t delay getting medical treatment, even if your injuries seem minor. Some injuries become more serious over time, and prompt medical attention creates a clear record linking your injuries to the incident. Keep all medical records and receipts for expenses related to your injury.
Contact a Legal Professional
Before talking to insurance companies or signing any documents, consult with a lawyer. Insurance adjusters may try to get you to make statements that could hurt your claim. California has strict time limits for filing injury claims, so it’s important to understand your rights quickly.
Protecting Your Rights After a Holiday Party Injury
California law provides strong protections for people injured at or after holiday parties. As the Purton case shows, employer liability can extend well beyond the party itself. If you’ve been injured, you don’t have to handle the aftermath alone.
At Penney & Associates, our experienced personal injury lawyers with deep trial experience are ready to fight for you. Contact us for a free consultation. The sooner you reach out, the better we can protect your rights. With offices across California, from Red Bluff and Sacramento to Bakersfield, Los Angeles, and beyond.
Read More
Crowd Control Failures on Black Friday: Legal Recourse for Injured Shoppers
Can Coaches and Schools Be Held Liable for Sports Injuries?
Policies, Settlements, and Pitfalls: A Quick Guide to Insurance Claims
