On Sept. 17, 2020, the New Jersey Supreme Court issued its decision in Estate of Narleski v. Nicholas Gomes. This is a significant case in which the court imposed a duty on a 19-year-old who hosted a gathering in his residence with other 19 and 20-year-olds where they consumed alcohol. The application and scope of the duty announced in Narleski will have profound implications for adults over 18 but under 21 who host underage drinking parties in their homes.

In Narleski, the court held that the 19-year-old host's liability was not dependent on whether he technically owned or leased the property. Instead, it is sufficient that a social host "knowingly permitted and facilitated the consumption of alcoholic beverages to underage guests in a residence under his control." Although the scope of "under his control" may need clarification in future cases—the court suggested that having a "key to the door" may be enough—this ruling covers those who host parties while living in their parents' homes, including college students home on break.