Dix v. Live Nation Entertainment, Inc.Annotate this Case
After Katie Dix ingested an illegal drug and collapsed while at a Live Nation electronic music festival, she was later pronounced dead from Ecstasy-related dehydration. Katie's parents filed suit against Live Nation for negligence and other causes of action. The trial court granted summary judgment for Live Nation. Plaintiffs contend that the trial court erred in granting summary judgment because Live Nation owed a duty of care to music festival attendees and that triable issues of material fact exist on their negligence cause of action.
The Court of Appeal reversed and held that, because of its special relationship with festival attendees, an operator of electronic music festivals like Live Nation owes a duty of reasonable care to festival attendees. The court explained that Live Nation's argument that it did not owe Katie a duty because she voluntarily consumed an illegal drug and died from acute drug intoxication may be relevant to causation or comparative fault, but not duty. Furthermore, after examining the Rowland factors, the court held that the foreseeability factors and policy factors weigh against finding an exception to the legal duty of ordinary care for operators of electronic music festivals. Finally, triable issues of fact for the jury to decide preclude summary judgment regarding breach of duty and causation.