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Wakulich v. Mraz | 751 N.E.2d 1 (2001)
In states with no social-host liability, supplying alcohol to guests isn’t enough to make someone liable for alcohol-related injuries. But social hosts may be on the hook under another theory, as we’ll see in Wakulich versus Mraz.
Sixteen-year-old Elizabeth Wakulich was at the home of the Mraz brothers, Michael and Brian, when they peer-pressured her into drinking a full quart bottle of Goldschläger liquor. Soon after drinking the Goldschläger, Wakulich lost consciousness. The Mraz brothers carried her downstairs to the family room and placed her on a couch, where they observed her vomiting and making gurgling noises. Later, when they came back to check on Wakulich, they changed her vomit-soaked shirt and placed a pillow under her head to prevent aspiration.
The Mraz brothers didn’t contact Wakulich’s parents, didn’t seek medical attention for her, and even prevented others in their home from calling nine-one-one. Eventually, they took Wakulich to a friend’s house. The friend took Wakulich to a hospital, where she died of alcohol poisoning.
Wakulich’s family brought a wrongful death action against the Mraz brothers, alleging that they owed Wakulich a duty of reasonable care after voluntarily undertaking steps to care for her. The trial court dismissed the case in favor of the Mraz brothers, and the Wakulich family appealed to the Illinois Appellate Court.
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