The Pennsylvania Supreme Court has held that as a matter of common law a commercial licensee of alcoholic beverages can be held liable for third party injuries which are proximately caused by the sale of alcohol to a minor.
Matthews v. Konieczny, ___ Pa.___ , 527 A.2d 508 (1987).
Bryan D. Kocher,
Tort Law - Common Law Negligence - Liability of Commercial Vendor of Alcohol - Duty Derived from Criminal Statute,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol26/iss3/12