October 7, 2026 · Updated October 21, 2026

Utah Supreme Court's 2026 Dramshop Ruling (RMB v. Celotto): No Contribution After Settlement

General information, not legal advice. Read the full disclaimer.

Short answer: On July 23, 2026, the Utah Supreme Court decided RMB, Inc. v. Celotto, 2026 UT 19, holding that Utah's Dramshop Act (Alcoholic Product Liability Act, Utah Code §§ 32B-15-101 to -302) does not allow a bar to seek contribution from the intoxicated driver for amounts the bar paid in a voluntary settlement with the injured person. The court affirmed the court of appeals, reading the word "award" in the contribution provision, § 32B-15-302(1)(a), according to its plain language. For crash victims, the practical effect is that a bar that settles a dramshop claim can't later turn around and seek contribution from the driver on the strength of the Dramshop Act.

Who this guide is for

People injured (or families who lost someone) in a crash involving an intoxicated driver who was served at a bar, and anyone following how Utah's dram shop law is applied.

What happened

According to the opinion, Corbin Celotto was in a crash with another driver, who sued Celotto for negligence and recklessness (alleging intoxication) and sued five bars under the Dramshop Act for overserving him. Two bars were dismissed, and the injured driver settled with Celotto and the three remaining bars. Two of those bars, RMB, Inc. and Shaman, Inc., then sought contribution from Celotto under § 32B-15-302(1)(a). The district court granted Celotto summary judgment, the court of appeals affirmed (2024 UT App 188), and the Supreme Court affirmed.

The statute and the holding

Section 32B-15-302(1)(a) lets "a person … against whom an award is made under this chapter" bring a separate cause of action for contribution against any person causing the injury and damage. The Supreme Court held that, based on the statute's plain language, the Act doesn't permit contribution for amounts paid under a voluntary settlement, and rejected the bars' arguments that common law principles and policy support a different reading. We have read the opinion's introduction and background; read the full opinion for its reasoning and any limits.

How a dramshop claim works (the baseline)

Under § 32B-15-201, a person who directly gives, sells or provides an alcoholic product as part of the commercial sale or service of alcohol is liable to a third person (or the third person's heirs) for injury or death if the product caused the intoxication of someone who was under 21, apparently under the influence, known or should have been known to be under the influence, or a known interdicted person, and the injury results from that intoxication. There is prima facie evidence of liability if the provider gave the last drink consumed at the location and the injury occurred within 30 minutes and 10 miles of leaving, and the driver was charged with DUI or (if killed) had a BAC of .05 or greater. Damages (other than punitive) are capped at $1,000,000 per person and $2,000,000 per occurrence for causes of action arising after January 1, 2010, and the deadline is two years from the injury (§ 32B-15-301). See Utah Dram Shop Liability.

What it may mean for victims

Settlement dynamics. Bars facing a claim can't count on recouping settlement dollars from the driver through the Act's contribution remedy, which may affect how they evaluate settling.
Your claim against the driver is separate. The statute says the Act doesn't preclude any cause of action against the person causing the injury, and such an action is exempt from the dramshop cap (§ 32B-15-301(4)). See Utah Drunk Driving Accident Victim Claims.
Contribution rules still matter in litigated cases. The Act's contribution right applies to an "award." The opinion addresses voluntary settlements; the effect on court-ordered awards isn't addressed in the portions we reviewed.

This is an overview, not legal advice about your case.

Frequently asked questions

What did the Utah Supreme Court decide in RMB v. Celotto?

That the Dramshop Act doesn't allow contribution claims for amounts paid in a voluntary settlement.

Does this change who can sue a bar?

No. It addresses a bar's contribution claim against the driver, not the victim's claim against the bar.

What's the deadline for a dramshop claim?

Two years from the date of the injury and damage (§ 32B-15-301(3)).

Is there a cap?

$1,000,000 per person and $2,000,000 per occurrence for causes of action arising after January 1, 2010.