Washington Law Review
The rule is well established that the operator of an automobile owes an invited guest a duty to exercise reasonable care inits operation, and will be liable to the guest for ordinary negligence which causes injury to him. Nevertheless, a few jurisdictions have adopted the rule that gross negligence must be shown in order to hold the operator liable to his invited guest, or stated conversely, that only slight care is required of the operator of an automobile toward his invited guest.
Frank L. Mechem & Lowell P. Mickelwait,
5 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol5/iss3/1