Is a bartender liable for injuries sustained by an intoxicated customer?

To understand these amendments, a brief review of the prior case law is helpful. Prior to 1978, under the doctrine of Cole v. Rush, 45 Cal.2d 345, 289 P.2d 450, the courts of this state held that as a matter of law bartenders were not liable for injuries caused by their sale of liquor to intoxicated customers. It was held that the consumption of alcoholic beverages and not their provision was the proximate cause of any injury to intoxicated customers or to third parties who were injured by intoxicated customers.