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All 50 States

Expert Witness Services by State

Ryan Dahlstrom accepts hospitality and entertainment expert-witness engagements in all 50 states and is retained by attorneys representing plaintiffs and defendants. The sections below summarize dram shop and liquor liability law in the state where your matter is venued.

Case Experience

Where Ryan Has Been Retained

Ryan Dahlstrom accepts expert-witness engagements in all 50 states. His case experience includes matters in Texas, Nevada, New Mexico, Illinois, Utah, Washington, California, New York, Kentucky and other jurisdictions, involving dram shop and liquor liability, security, premises liability, hospitality operations, event safety, restaurant management and bar operations.

Alcohol Service

Dram Shop and Liquor Liability by State

States take very different approaches to alcohol-service liability. Most allow a claim against a licensed establishment that served a visibly or obviously intoxicated person. Some limit the claim to service to minors, and a few do not allow claims against licensed sellers for serving adults. Where a state has no traditional dram shop claim, liquor liability issues can still arise through social-host rules, service to underage persons, and related premises liability and security claims. Each summary covers the governing statute or case law, the standard of proof and the state alcohol regulator.

AlabamaDram Shop Act — "contrary to law"AlaskaLicensed-provider liability under AS 04.21.020ArizonaStatutory claims only, under A.R.S. § 4-311Arkansas1999 Dramshop ActCaliforniaLicensee immunity, narrow exceptionColorado"Willfully and knowingly" — a high barConnecticutStatutory cap and a short notice windowDelawareNo dram shop cause of actionFloridaImmunity with two narrow exceptionsGeorgiaNoticeably intoxicated + knowledge of drivingHawaiiCommon-law liquor liabilityIdahoObvious intoxication + 180-day noticeIllinoisDramshop Act and statutory capsIndianaActual knowledge requiredIowaDramshop Act with mandatory liability insuranceKansasNo dram shop remedyKentuckyReasonable-person knowledge standardLouisianaAnti-dram shop statuteMaineMaine Liquor Liability Act — negligent and reckless serviceMarylandNo dram shop liability — Warr v. JMGM GroupMassachusettsNegligence built on the service prohibitionMichiganName-and-retain requirementMinnesotaCivil Damage Act and written noticeMississippiImmunity except visible intoxicationMissouriClear and convincing evidenceMontanaExclusive statutory remedy, capped, 180-day noticeNebraskaNo adult-service claim; minor-service route onlyNevadaNo dram shop cause of actionNew HampshireComprehensive statutory liability chapterNew JerseyLicensed Server Fair Liability ActNew MexicoReasonably apparent intoxicationNew YorkEvent venues and the Dram Shop ActNorth CarolinaTwo routes — intoxicated persons and minors, with a capNorth DakotaObviously intoxicated — knowing serviceOhioKnowing service to a noticeably intoxicated personOklahomaCommon-law duty under BriganceOregonVisible intoxication + 180-day written noticePennsylvaniaVisible intoxication under the Liquor CodeRhode IslandLiquor Liability ActSouth CarolinaCommon-law negligence, no dram shop actSouth DakotaStatutory return to common-law non-liabilityTennesseeBeyond a reasonable doubt — a jury findingTexasSafe HarborUtahApparently under the influenceVermontDram Shop Act, revised 2023VirginiaNo dram shop cause of actionWashingtonApparently intoxicated personsWest VirginiaUnlawful sale under the ABC ActWisconsinBroad immunity with three narrow exceptionsWyomingImmunity for lawful service

Which State Is Your Matter In?

Submit a case inquiry for a confidential conflicts check. Ryan is retained by plaintiff and defense counsel and accepts engagements in all 50 states.