Illinois Supreme Court Holds: National Fraternity Organizations Owed No Duty to Local Pledge Who Died During Alcohol-Related Hazing Event
By Michael J. Bankhead
On January 19, 2018, as a matter of first impression, the Illinois Supreme Court in the case of Bogenberger v. Pi Kappa Alpha Corporation, Inc. et al., 2018 WL 476648 (2018), found that the Pi Kappa Alpha national and international organizations (“Nationals”) owed no duty to a local pledge who died from alcohol intoxication during a mandatory pledge event at a local chapter, in which pledges were required to consume excessive amounts of alcohol.
The Supreme Court held that there was no special relationship between the Nationals and the pledges that would impose direct liability, and there were insufficient allegations of control by the Nationals over the local chapter that would establish agency for the purpose of holding the Nationals vicariously liable for the local chapter’s actions. The Supreme Court also held that the local chapter, its members and officers, and several non-member sorority women who planned and carried out the event did owe a duty to the deceased pledge, and could be held liable for negligence, by creating a limited exception to the rule against social host liability for injuries caused by alcohol-related hazing events.
Click here for a more detailed summary of the Court’s decision.