Palace Hotel Co. v. Medart

87 Ohio St. (N.S.) 130
CourtOhio Supreme Court
DecidedNovember 26, 1912
DocketNo. 12969
StatusPublished

This text of 87 Ohio St. (N.S.) 130 (Palace Hotel Co. v. Medart) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Palace Hotel Co. v. Medart, 87 Ohio St. (N.S.) 130 (Ohio 1912).

Opinion

O’Hara, J.

The principal error relied upon by plaintiff in error, and which presents a question of some importance, is raised with reference to the charge of the court. The court charged the jury, in substance, that proof that plaintiff was a guest of the hotel at the time of the loss, that he had been accepted as such and had duly left the property above described in his room in the hotel, and that it was taken therefrom without his knowledge or consent, would establish a prima facie case and put the defendant upon its proof. This is claimed to be erroneous, in that the charge did not require affirmative proof by plaintiff of negligence on the part of the defendant, which it is claimed was required by Section 4427a, Revised Statutes, then in force, now Section 5983, General Code. That section, which was originally passed April 27, 1896 (92 O. L., 322), reads as follows: “The liability of the keeper of any inn, whether individual, partnership, or corporation, for loss of or injury to personal property placed by his guests under his care, other than that described in the preceding section, shall be that of a depositary for hire; provided, however, that in no case, shall such liability exceed the sum of one hundred and fifty dollars for each trunk and its contents, [133]*133fifty dollars for each valise and its contents, and ten dollars for each box, bundle or package, and contents, so placed under his care, unless he shall have consented in writing with such guest to assume a greater liability.”

It is claimed on behalf of plaintiff in error that, by the enactment of the above section of the statutes, the common law liability of an innkeeper was changed from that of practically an insurer of the goods of his guest to that of a depositary for hire; and also, by necessary intendment, that affirmative proof of negligence on the part of the innkeeper is required under the statute before he can be held liable, because a depositary for hire is bound to exercise ordinary care only, and is responsible only for his neglect so to do.

The question raised is one of general interest, and affects the entire traveling public as well as the many hotels throughout the state. Numerous statutes have been passed in the various states upon this subject, but nevertheless there are few, if any, decisions that bear directly upon the proposition here presented.

In order to arrive at a proper solution of the question, it is necessary to consider the nature of the relation of an innkeeper to his guests, and his duties and responsibilities as fixed by the common law. In his interesting work on this subject, Professor Beale has given a brief history of the development of inns, and he draws the conclusion, that from the earliest times the fundamental characteristic of an inn has been its public nature. Beale on Innkeepers, Section 11. The [134]*134meagre facilities for travel, and the unsettled condition of the country in medieval England, resulted in the adoption of a very strict responsibility on the part of innkeepers to the public, and what is known as the common law rule of liability was adopted. This has been stated in various ways, but as commonly accepted, it is, in substance, that an innkeeper is liable for the goods of the guest lost in the inn, unless the loss has been caused by act of God, or of a public enemy, or by fault of the owner. Beale on Innkeepers, Section 185. 22 Cyc., 1081. And the rule of the common law has always been recognized by this court as in force in this state. Gast v. Gooding, 7 W. L. J., 234, 1 Dec. Re., 315; Fuller v. Coats, 18 Ohio St., 343, at pages 349 and 350.

The public character of the innkeeper’s relation is further shown by the statutes of Ohio, which provide that all persons within the jurisdiction of the state shall be entitled to the full and equal enjoyment of the accommodations, advantages, facilities and privileges of inns, restaurants, eating houses, and other places of public accommodation and amusement; and a denial of these rights to any citizen by any person is made a misdemeanor punishable by fine and imprisonment. Sections 4426-1, 4426-2, Revised Statutes, now Sections 12940, 12941, General Code..

It seems to be universally settled, however, that no matter what view is taken as to the degree of responsibility of the innkeeper under the common law rule, upon loss or injury to the goods of a guest being shown, the innkeeper is prima facie [135]*135liable and the burden is upon him to establish such facts as will exonerate him. Beale on Innkeepers, Section 190. 22 Cyc., 1082.

The foregoing is conceded by counsel for plaintiff in error, but he claims that the common law rule in this state was materially modified by the passage of the act of March 3, 1860 (57 O. L., 15), which subsequently became Section 4427, Revised Statutes, now Sections 5981, 5982, General Code, and also by the act of April 27, 1896, above referred to, being Section 4427a, Revised Statutes, General Code, Section 5983. The former statute makes provision for the custody of money, bank notes, jewelry, negotiable papers, and other valuables, and limits the liability of an innkeeper therefor, under certain conditions. We are not concerned with this section of the statutes at the present time, however, but are confined to a consideration of the meaning and scope of the latter section, 4427a, which covers personal property placed under the care of an innkeeper by his guests, other than that described in the preceding section.

Although the petition was evidently drawn with reference to Section 4427a, and the court charged the jury upon the theory that the case was governed thereby, counsel for defendant in error now claim in their brief that the statute has no application to the facts herein. It is contended that this section was not intended to apply to personal property of -the guest other than money, jewelry, etc., left by him in his sleeping room, but only to such as are directly placed in the care of the [136]*136innkeeper, that is, to be kept in his check room or storage room. This question was very briefly presented on behalf of defendant in error, and was not discussed in the brief for plaintiff in error, although its counsel urged upon the court at oral argument that a judicial construction of this statute is greatly desired, the rights of hotel-keepers and guests thereunder being matters of much public interest and concern.

We have accordingdy given the question some consideration, and are inclined toward the opinion that there is force in the contention of defendant in error. Section 4427a was originally enacted on April 27, 1896 (92 O. L., 322), as “supplemental” to Section 4427, which was then amended and re-enacted, and both were made parts of what was designated “An act to amend and supplement Section 4427 of the Revised Statutes of Ohio.” The supplemental section expressly refers to the other, and they seem to be component parts of one plan or purpose, which is to provide a limitation upon the amount of the liability of the innkeeper for the property of every sort or description of his guest, that may or should be directly placed in his charge.

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Bluebook (online)
87 Ohio St. (N.S.) 130, Counsel Stack Legal Research, https://law.counselstack.com/opinion/palace-hotel-co-v-medart-ohio-1912.