Manuel v. Koonce

In Manuel v. Koonce, 206 Ga. App. 582 (425 SE2d 921) (1992) the defendants' 16-year-old son had a party at their home where they left him when they went out of town for a long weekend. One of the guests who consumed alcohol at the party crashed his truck into a van that night, killing multiple people. See id. at 583 The evidence established that the defendants had specifically instructed their son not to have any parties at their home or to "be involved in the use of alcohol" during their absence. See id. at 583 (1). There was no evidence that their son had ever consumed alcohol at their home, provided alcohol to others at their home, or hosted a party there where he had provided his friends with alcohol. See id. The defendants had, however, been summoned by the police on a prior occasion after their son was found drinking alcohol. See id. at 583-584 (1). The Court held that the defendants were entitled to summary judgment because there was no evidence establishing that they knew or should have known that their son had a propensity for making alcohol available to underage guests at their home during their absence. See id. at 584-585 (1) (b). The Court also noted that although the defendants may have had notice of their son's personal propensity to consume alcohol away from his home, "it did not place them on notice that he had any propensity whatsoever to violate their explicit orders and furnish alcohol to others at their home." Id. at 585 (1) (b).