Liability, Prosecution and Risk Minimization
INTRODUCTION
ARF'S* COMMITMENT TO REDUCING ALCOHOL-RELATED HARM IN ONTARIO COMMUNITIES
The Addiction Research Foundation* is an agency of the Province
of Ontario committed to creating and applying research-based
knowledge to reduce the harm caused by the abuse of alcohol
and other drugs. To meet this goal, we work with others who
share our vision of an Ontario free from the suffering caused
by alcohol and other drug use.
The information in this booklet is provided to help municipal
leaders understand alcohol-related risks and develop a policy
strategy to reduce them. Other community stakeholders should
also find this information helpful in creating healthier and
safer communities.
Municipalities with policies governing the use of alcohol in
their recreation facilities are reporting reductions in
alcohol-related problems and little, if any, decrease in
facility rentals. Those municipal officials who would like to
benefit from the development of a Municipal Alcohol Policy
(MAP) should contact our Community Programs Staff for
assistance and information.
P.R.W. Kendall, MBBS, Msc., FRCPC
President and CEO
Addiction Research Foundation*
ACKNOWLEDGEMENTS
The Addiction Research Foundation* extends its appreciation to
the Drinking/Driving Countermeasures Office, Ontario Ministry
of the Attorney General for assistance in developing and
producing this community resource.
This pamphlet was written by:
R. M. Solomon, Professor, Faculty of Law, University of Western Ontario
S. J. Usprich, Professor, Faculty of Law, University of Western Ontario
R. R. Douglas, Community Programs, Addiction Research Foundation
L. Kiss, LLB, Student at Law
L. Prout, LLB, Student at Law
THE GROWING RISKS
In 1989, the Metropolitan Toronto Conservation Authority was
held liable for over $215,000 when several intoxicated campers
attacked the McGinty family. Although the campground was
advertised as a quiet family place, staff largely ignored the
McGintys' complaints about the assailants' noisy party. Later
that evening, Mr. McGinty was badly beaten when he rushed over
to the party in response to cries for help. The court held the
Conservation Authority liable for failing to take reasonable
steps to control the assailants' conduct. Despite previous
incidents with the assailants that summer and a violent
confrontation earlier that evening, staff did not eject them
or try to prevent further problems.
This case shows the expanding liability for all alcohol-related injuries. The numbers and types of these civil suits
have increased dramatically across Canada, particularly in
Ontario. Contrary to popular belief, it is not only taverns
and businesses that are being sued. Claims have also been
brought against municipalities, universities, service clubs,
government alcohol outlets, private social hosts, common
carriers, police, and sponsors of alcohol-related events.
This booklet is designed to help municipal officials,
politicians and volunteers understand their potentail
liability and the need for municipal alcohol policies-
particularly for municipally-owned recreation facilities.
First, we outline cases in which a municipality may be held
liable. Then we briefly explain the main rights and
obligations of municipalities. Finally, to help municipalities
in designing their own risk minimization program, we outline
a process for developing a Municipal Alcohol Policy (MAP) and
suggest some measures to introduce safer practices.
WHEN CAN MUNICIPALITIES BE SUED?
LIABILITY FOR PROVIDING ALCOHOL
In the landmark case of Jordan House Ltd. v. Menow, the
Supreme Court of Canada imposed a duty on alcohol providers to
protect their intoxicated patrons. In this case, Hotel staff
had ejected Menow, a regular patron, after he had become
intoxicated and annoyed other customers. While staggering
along the highway, Menow was hit by a negligent driver. Menow
sued both the driver and the Hotel. The Supreme Court of
Canada unanimously upheld both claims although two views
emerged concerning the Hotel's liability.
One judge emphasized that the staff knew that Menow was
irresponsible when intoxicated, violated provincial law in
serving him when he was intoxicated, and ejected him even
though they knew he had no safe way to get home. According to
this judge, the staff should have tried to protect Menow by
allowing him to spend the night in one of the Hotel's rooms,
by calling the police or by arranging safe transportation
home. Another judge defined an alcohol provider's liability
more broadly. He believed that the staff neglected their
common-law duty by serving Menow past the point of
intoxication. Their obligation was to prevent intoxication and
not just to protect patrons after they became intoxicated.
This broader definition of a provider's duty has largely
prevailed. In later cases, providers have been held liable
even though they did not know about the person's
susceptibility to alcohol, did not know about the person's
intoxication, and had not ejected the person. Providers may
also be liable even though they did not provide all or even
most of the alcohol that causes a customer to become
intoxicated. Instead, providers must not serve alcohol to
anyone past the point of intoxication or to someone who is
already intoxicated. Providers who neglect this duty may be
liable for any injuries that customers cause or suffer, either
on or off the premises.
While there is a clear trend towards expanding liability, the
exact bounds of a provider's liability are still evolving. For
example, an Ontario court recently held that a tavern was not
liable for serving one beer to an intoxicated patron, because
the staff had not had a sufficient chance to assess his
intoxication. Nevertheless, the court stated that once the
staff realized that the patron was intoxicated, they had a
duty to prevent him from driving even if they had to call
the police.
LIABILITY AS AN OCCUPIER
A municipality can also be held liable as an "occupier" for any
alcohol-related injuries that occur on its property. The
Ontario Occupiers' Liability Act defines an occupier as
anyone who controls the premises and has the power to admit or
exclude entrants. The Act requires occupiers to take
"reasonable steps" to ensure that all entrants are "reasonably
safe while on the premises." Depending on the facts, several
parties may be considered to be co-occupiers of a place. For
example, if a dance is held at a municipal hall, the occupiers
could include the club that is renting the hall, the caterer
who is managing the event, and the municipality that is
providing security and janitorial staff. Although it is not
widely known, occupiers' liability has accounted for more
alcohol-related suits than providers' liability. The following
section discusses some types of situations in which occupiers
may be held liable.
Physical Condition of the Premises:
Like other occupiers, licensees must ensure that their
premises are reasonably safe for their patrons. In Niblock v.
Pacific National Exhibition, an extremely intoxicated man was
seriously hurt when he fell over a low railing on a steep
staircase. The railing was several inches lower than the
building code required. The injured man sued Pacific National
Exhibition and the City of Vancouver, which both attributed
the accident solely to the man's intoxication. In rejecting
this argument, the court emphasized that the British Columbia
Occupiers' Liability Act (like its Ontario counterpart)
requires that occupiers ensure that their premises are
reasonably safe for anyone who may foreseeably enter. Since
there were three licensed premises on the grounds, some
patrons could be expected to become intoxicated. In holding
the Exhibition liable, the court ruled that the premises had
to be reasonably safe not only for sober patrons, but also for
intoxicated customers if their presence was foreseeable.
A municipality can also be held liable as a landlord under
the Ontario Occupiers' Liability Act for injuries that are
caused by the physical condition of its facilities.
Consequently, a municipality that rents its community hall for
a wedding may be held liable if an intoxicated guest falls
down a poorly lit staircase, slips on a loose carpet or walks
into a glass patio door.
Conduct of the Entrants:
As the McGinty case shows, occupiers may be held
accountable for the conduct of people whom they have allowed
to enter or to remain on their premises. Before the Occupiers'
Liability Act was introduced in 1980, the courts focused on
the foreseeability of the incident that is, they considered
whether the assailant was known to be violent or showed signs
of becoming violent. Now, however, occupiers may be held
liable for simply tolerating a situation in which violent or
careless behaviour is foreseeable, even if the specific
incident is not.
This reasoning may have prompted the $700,000 settlement
in the Munier case. In this case, an intoxicated young man
became a quadriplegic after he started a fight at a large
"bush party" hosted by a farmer's son. None of the 300 youths
who attended the party was formally invited; nor did the
farmer or his son supply them with alcohol. The farmer was
sued as an occupier simply for allowing an event on his
property that he knew or ought to have known posed foreseeable
risks of injury. Previous bush parties had also resulted in
problems. Municipalities cannot afford to ignore patrons or
guests who are becoming hostile or to continue to hold events
on their property that have posed problems in the past.
Activities on the Premises:
In Jacobson v. Kinsmen Club of Nanaimo, the Club sponsored
a "Bavarian beer garden" in a large curling arena. During the
festivities, patrons entertained the crowd twice by climbing
a support beam and "mooning" those below. Later, when a patron
known only as "Sunshine" tried to mimic these actions, he lost
his grip and fell 30 feet onto Jacobson, knocking him
unconscious. Sunshine was unharmed in the incident and left
shortly afterwards. Jacobson sued the Club for allowing this
unsafe activity on its premises. The court stated that the
Club would not have been held liable if the injury had
occurred during one of the first two climbs. However, by the
time Sunshine climbed the beam, staff should have recognized
the possible danger to the patrons. The court concluded that
by not stopping Sunshine, the Club failed its duty as an
occupier and was liable. City staff, volunteers and security
must step in before foreseeably dangerous activities cause
injuries and potential law suits.
ADDITIONAL BASES OF LIABILITY
Sponsoring Activities:
In 1988, the Supreme Court of Canada held a resort liable
for injuries that Crocker, an intoxicated guest, suffered
while participating in the resort's tube-racing contest.
Although staff had tried twice to discourage Crocker from
racing, the court viewed their efforts to be insufficient. The
court found that sponsors of potentially dangerous events have
a duty to prevent intoxicated persons from participating, even
if the sponsor did not contribute to the person's
intoxication. As the sponsor, the resort should have prevented
Crocker from competing by disqualifying him, postponing the
event or calling the police. The sponsor's obligation to take
preventive actions increases with the dangerousness of the
event and the participant's apparent intoxication.
Transporting the Intoxicated:
By providing transportation to the intoxicated,
municipalities and those who rent their facilities have legal
obligations in their role as "common carriers." First, common
carriers may be held liable for ejecting an intoxicated
passenger who is in a helpless condition. For example, in
Dunn v. Dominion Atlantic Railway Co., the Supreme Court of
Canada held the Railway liable for the death of an intoxicated
passenger, who was hit by a train after he had been ejected at
a closed, unlit station late at night. Second, common carriers
must take reasonable care to prevent intoxicated passengers
from injuring others. However, carriers will not be held
accountable for every injury an intoxicated passenger causes
only for those that are reasonably foreseeable and
preventable.
Use of Excessive Force:
Using unnecessary or excessive force to manage intoxicated
persons seems to have produced more civil suits than either
providers' or occupiers' liability. In Ekblad v. Commonwealth
Holiday Inns of Canada, a customer argued persistently with
the doorman over whether he could have a candle on his table.
When the patron followed the doorman to repeat his request,
the doorman punched him in the face, knocking him unconscious.
The judge said that even if the doorman was justified in using
force to resolve this verbal dispute, striking the patron in
the head was unreasonable in these circumstances.
Consequently, both the doorman and the Inn were held liable to
the patron for over $250,000. The case shows that force cannot
be used to teach a patron a lesson, to settle a verbal dispute
or to enforce house rules. Nor can force be used once the
person has been subdued or ejected. What constitutes
unnecessary force or excessive force will depend on the
specific facts of the case.
Liability of Police:
Police can be sued for failing to protect and control the
intoxicated in a growing number of situations. This trend is
important to municipalities, which are ultimately liable for
police activities. First, police may be held responsible for
using unnecessary or excessive force in managing intoxicated
persons. Second, they may be liable for negligently
supervising intoxicated prisoners who, for example, set fires
in their cells or commit suicide while in custody. Third,
police have been sued for negligently enforcing laws
concerning drinking and driving. For example, an officer who
does not arrest an obviously intoxicated driver may be held
liable if that driver later causes an accident. Finally,
police may be held responsible for negligently failing to get
medical help for an intoxicated suspect who they know or
ought to know needs medical help.
Similar liability principles would apply to "off-duty"
police officers who were hired to provide security at a
municipal or private event. Thus, an officer could be held
liable for not trying to stop a fight or for allowing
intoxicated patrons to drive away from the event.
Liability of Volunteers, Sponsoring Clubs and Facility Renters:
The fact that municipalities' potential liability has
expanded dramatically in recent years does not limit the
liability of those who run, sponsor or host the event. These
individuals, groups and organizations can and will be sued for
alcohol-related injuries that their events cause. They will be
named as defendants and can be held liable as well as the
municipality. In fact, a municipality may try to reduce its
own losses by naming the sponsor or organizer as co-defendants.
MUNICIPALITIES' LEGAL RIGHTS AND OBLIGATIONS
Those responsible for managing municipal facilities where
alcohol may be served should understand their rights and
obligations under provincial alcohol laws. First, the scope of
liability is broad. Anyone who knowingly helps in an offence
or directs someone to commit an offence may be found guilty
along with the main offender. Also, any director or officer of
a corporation who allows an offence to occur may be personally
prosecuted. Thus, a server, manager, municipal officer and the
municipality may all be found guilty of a single offence.
Second, violations of the law may result in severe penalties
and licensing consequences, including a municipality's liquor
licence being suspended or revoked. Third, even if no party is
prosecuted, any violation of the provincial alcohol law may
undermine a municipality's legal position in a later civil
suit. Finally, the legislation gives providers broad powers
that can be used to eliminate many of the situations that lead
to legal difficulties. Here are some of the key sections:
GENERAL PROVISIONS
- It is an offence to sell or provide alcohol to a person who is or appears to be intoxicated. In civil cases, the courts typically consider intoxication to be a blood-alcohol level above .08 per cent.
- Anyone under age 19 is prohibited from drinking, buying, attempting to buy, or otherwise obtaining alcohol. Although under-age persons may be allowed to enter licensed premises, they must not be served alcohol or be allowed to drink alcohol.
- It is an offence to have or drink alcohol in any place other than a home, private place, or a facility that has a licence or permit. Consequently, it is illegal for a person to drink in a public park, beach, recreation centre lobby, street, or stadium parking lot.
- It is an offence to be intoxicated in a public place.
REGULATORY PROVISIONS
- The legislation narrowly defines permissible advertising. For example, a licensee is generally restricted to advertising only the name of the establishment, the fact that it has a licence and the general types of liquor sold. Similar
restrictions apply to advertising events that are held under most types of special occasion permits. For example, advertising is not permitted for a non-profit reception.
- The alcohol legislation greatly limits the marketing practices of alcohol manufacturers. For example, manufacturers may not give free alcohol to any person, except as permitted by law. Manufacturers also cannot give inducements to a
licensee or permittee in return for preferential treatment of their products.
- Similarly, licensees and permittees cannot seek or accept inducements from manufacturers. Thus, if a beer manufacturer
pays for the band at a municipal dance in return for preferential promotion of its products, both the manufacturer and the municipal licensee or permit holder would be violating the law.
- Licensees and permittees cannot allow drinking contests, or give patrons free alcohol volume discounts, or prizes of alcohol.
- The alcohol legislation requires licensees and permittees to eject patrons who are unlawfully present or acting unlawfully. If these patrons refuse to leave, licensees can use reasonable force to remove them.
- Licensees must not allow drugs, drunkenness, and riotous or violent conduct on the premises.
- Licensees and permittees have broad rights to deny entry to and eject anyone whose presence is undesirable. The term "undesirable" includes anyone whose presence would violate the
legislation, such as intoxicated, violent or quarrelsome patrons. However, the right to deny entry is not absolute; it
cannot be used to bar liquor inspectors and police, or used in a way that violates human rights legislation.
RELATED POWERS
- Ontario's trespass legislation gives occupiers even broader powers to control who may enter and remain on the premises, and additional authority to use force.
- The Criminal Code gives occupiers extensive powers to eject trespassers and to arrest anyone who is committing criminal offences on the property. The Criminal Code also authorizes all individuals to use force in self-defence, defence of others and defence of property.
- While occupiers may have authority to use physical force in certain limited circumstances, every effort should be made to resolve the conflict peacefully. There is civil and criminal liability for those who use unnecessary or excessive force.
DEVELOPING A MUNICIPAL ALCOHOL POLICY
Municipalities traditionally have developed policies in response to problems as they arise. However, adopting isolated initiatives such as designated driver programs and waivers of liability, may do more harm than good if they provide individuals with a false sense of security. Given their broad exposure to liability and prosecution, municipalities need an effective planning process to develop a comprehensive policy. We recommend the following process for developing a MAP and also provide suggestions for implementing the policy and attaining community compliance.
BETTER POLICY FORMULATION
Involving the community in developing the policy will encourage facility users to comply with the policy. Listed below are some guidelines for developing an alcohol management policy. The process involved in developing the policy will allow the municipality to retain corporate leadership, involve community facility users, include existing good practices, and retain expert advice.
- Municipal leaders who wish to develop a MAP should consult with staff from a Community Programs Office of the Addiction Research Foundation (ARF*) [1] and/or Public Health Unit (PHU). who have skills in developing alcohol management policies. Similarly, citizens who want their Municipal Council to consider this policy option are encouraged to seek ARF*/PHU input.
- Once it has been decided that an alcohol management policy would benefit the municipality, it is advisable to formally obtain senior management support to proceed preferably through a motion from Council.
- Involve other municipal departments, facility users, and community stakeholders in developing the policy. We recommend forming a policy committee possibly involving municipal recreation staff, municipal solicitors, city/town/township volunteers, police, service clubs, sport groups, and drinking/driving countermeasure groups. Some stakeholders, however, may be unable to participate as members of the policy committee. In these cases, invite liquor inspectors, fire fighters and other community organizations to participate on a limited basis or to attend a special public meeting.
- Outline terms of reference to guide the policy committee's work. For example, committee members might be asked to inspect municipal facilities, identify alcohol-related problems, review existing serving/management practices, examine the Liquor Licence Act, attend a server training course, review case law, and discuss the research on drinking practices.
- A municipal representative should be assigned as the chair of the committee and /PHU staff as ongoing consultants. The committee should meet ARF* several times at three-week intervals to draft a policy for Council approval. Inform municipal leaders and other interested parties of the committee's discussions by circulating the minutes of all meetings.
- City officials should review the draft policy and, along with the policy committee, present it to Senior Management/Council for approval.
- Following the first year of operation, municipal staff may choose to review the impact of implementing the policy (such as reported vandalism, public complaints, police intervention, fights, LLBO investigations, injuries, etc.). If changes are suggested, a further report should be made to Senior Management/Council.
EFFECTIVE POLICY IMPLEMENTATION
Developing a MAP actually starts the implementation process since involving users in creating policy introduces them to the new regulations. Public participation should also increase the number of community members who willingly comply with the policy. Although some enforcement will be needed, the goal of implementing a policy is to gain voluntary community compliance by promoting the benefits of the policy to users. Therefore, we provide the following suggestions:
- A municipal employee usually someone in recreation and leisure services should design an implementation strategy. This person may choose to work with a marketing specialist. Since ARF*/PHU staff may have been involved in developing the policy and may have access to other initiatives in the province, the municipality should consult with them throughout this process.
- The implementation process should promote the benefits of the policy to various users of municipal facilities. These benefits may include: avoiding prosecution or loss of the liquor licence; reducing the chance of being sued for contributing to an accident; attracting tourists because they will not be assaulted by a drunk; providing groups with equal access to facilities; and improving the quality of community life by not offering events that contribute to health, social and public order problems.
- The municipality should launch a campaign to inform user groups and the public about the policy. The policy can be promoted through public service announcements (PSAs) on radio and television, news stories and public meetings, as well as by posting signs and handing out pamphlets. The policy can also be printed in municipal publications.
- The municipality can offer ongoing server training courses for staff and community groups.
- Some regulations in the policy may have to be reviewed by the legal department and passed by Council as by-laws.
- Any staff whose responsibilities are affected by the policy should have new duties added to their job descriptions. Some staff may need an orientation meeting to provide them with information about the policy and their new responsibilities.
- The implementation strategy should last at least a year, with periodic public information campaigns to introduce the policy to new users and to remind existing users of the policy and its benefits.
POLICY IMPACT ON FACILITY USE AND PROBLEM REDUCTION
A MAP should be sufficiently detailed to cover all facilities
and programs in which a municipality allows alcohol to be
served by its staff, volunteers, user/rental groups, and
caterers. The policy should focus on setting effective
management practices to reduce accidental deaths, injuries,
liquor-licence violations, and criminal prosecution. The
policy should reinforce serving alcohol responsibly to prevent
intoxication and supervising the intoxicated if someone
becomes intoxicated. If your municipality wishes to review a
policy, samples are available from the Addiction Research
Foundation's Community Programs Offices.
An ARF* survey [2] of Ontario municipalities estimated that
approximately one-third of cities, towns, townships and
villages with facilities that can host alcohol events had
developed or were developing a formal written policy. Of those
with completed policies, nearly 50 per cent reported that
facility rentals have remained the same or increased since
adopting an alcohol management policy. Of the remaining
municipalities with policies, seven per cent indicated that
they were uncertain and 23 per cent believed that it was too
soon to assess the effects. Only 22 per cent experienced some
rental loss.
Approximately 41 per cent of the municipalities with policies
reported reductions in one or more of the following problems:
under-age drinking, fights, vandalism, police interventions,
public complaints, injuries, legal actions, unlicensed
drinking, intoxication, LLBO penalties, and drinking and
driving. The other municipalities were uncertain or indicated
that their policies had not been in effect long enough to have
an impact.
Generally, municipalities reported a decline in problems six months after adopting their MAPs with minimal, if any, reductions in rentals.
LIP SERVICE WON'T DO
Given the current laws, it is not enough simply to talk about "responsible serving practice" and "moderate consumption." Nor will drafting new policies have much effect by itself. Progress will not occur until the practices of staff, volunteers and groups renting municipal facilities change. To achieve this change, municipalities must take effective action to publicize, implement and enforce their policies. Unfortunately, failure to do so will be measured in alcohol-related deaths, injuries, civil suits and prosecutions.
ENDNOTES
- Locations of Community Program Offices can be obtained by phoning the ARF* Information Centre: Metro Toronto (416) 595-6111; Ontario Toll-Free 1-800-INFO-CAMH (1-800-463-6273).
- For a complete report of the survey findings, contact Dr. Louis Gliksman, Scientist, Centre for Addiction & Mental Health, The Gordon J. Mogenson Building, 100 Collip Circle, Suite 200, University of Western Ontario Research Park, London, Ontario, N6G 4X8. Tel.: (519)858-5010 ex. 2000. Fax: (519)858-5199.
* Now the Centre for Addiction and Mental Health
[This is an excerpt from the CAMH publication entitled "MUNICIPAL ALCOHOL POLICY: LIABILITY,
PROSECUTION AND RISK MINIMIZATION, INFORMATION FOR ONTARIO COMMUNITIES", January, 1996.]