The Utah Supreme Court ruled that bars cannot seek contribution from a driver after settling a claim, clarifying the interpretation of the Dramshop Act. This decision affects bars and establishments that serve alcohol, as it limits their ability to recover costs from individuals involved in accidents where they have been deemed partially responsible.
In the case of RMB, Inc. and Shaman, Inc. v. Corbin G. Celotto, the court addressed whether the term "award" in the Alcoholic Product Liability Act, also known as the Dramshop Act, includes amounts paid as part of a voluntary settlement. The court's ruling, issued on July 23, 2026, confirms that the term does not encompass settlements, thereby impacting future liability claims involving alcohol-serving establishments.
Background
The case originated from a motor vehicle accident involving Corbin Celotto and another driver. The other driver sued Celotto for negligence and recklessness, alleging that he was intoxicated during the incident. Additionally, the other driver filed claims against five bars under the Dramshop Act, claiming they overserved Celotto before the crash. After two bars were dismissed from the lawsuit, the other driver settled with Celotto and the remaining three bars for a total of $1 million.
Despite the settlement, two of the bars, RMB and Shaman, sought contribution from Celotto, arguing that the Dramshop Act allowed them to recover costs from him. Celotto moved for summary judgment, stating that the term "award" in the Act does not include amounts paid in settlements. The district court agreed, dismissing the bars' claims and leading to an appeal.
The Ruling
The Utah Supreme Court affirmed the lower court's decision, stating that the Dramshop Act does not permit a party to pursue contribution claims after voluntarily settling a claim. The opinion, authored by Associate Chief Justice Pohlman, emphasized that the term "award" in the statute is not ambiguous and does not include voluntary settlements. The court stated, "the legislature employed language in the contribution provision that reflects its policy choice to allow for contribution only when an award has been made against a party."
The court's ruling clarified that the bars were not "persons...against whom an award [was] made" since they voluntarily settled the claims against them. The court concluded that no award was made against the bars, and therefore, they could not pursue a contribution claim against Celotto.
Impact
This ruling has significant implications for bars and alcohol-serving establishments in Utah. It establishes a clear boundary regarding their liability and ability to seek recovery from individuals involved in accidents after settling claims. The court's interpretation of the Dramshop Act reinforces the idea that settlements do not constitute awards under the law, which could discourage bars from pursuing litigation in similar circumstances.
Additionally, the decision may affect how future cases involving the Dramshop Act are handled. Bars may need to reconsider their liability strategies and how they approach settlements in cases involving intoxicated patrons. The ruling serves as a reminder that the language of statutes can significantly influence legal outcomes, particularly in liability cases.
What's Next
Details were not available in the court filing regarding whether this case can be appealed further. However, as the Utah Supreme Court has issued a definitive ruling on the matter, it is likely that the decision will stand unless new legal grounds emerge or related cases arise in the future.