Sanford v. LawlerAnnotate this Case
Plaintiffs, Joseph and Suzanna Sanford, filed suit against a beach resort for damages resulting from an injury Joseph received during an assault committed by James Lawler when all the parties were guests of the resort. James was staying at the resort with his parents and siblings, and James’s father assumed responsibility for the cost of the family stay at the resort. As relevant to this appeal, Plaintiffs asserted dramshop liability claims against the resort. The district court granted summary judgment for the resort, concluding that no sale took place because James did not provide any consideration for the alcoholic beverages served to him. The Supreme Court reversed, holding that the district court erred in interpreting the word “sold” in Iowa Code 123.92(1)(a) to only apply to direct sales, as third-party beneficiaries fall within the rubric of a sale for purposes of section 123.92(1)(a), and the sale in this case encompassed the entirety of the contracted goods and services.