CHAPTER 6
Negligence and
Hospitality Practices
CONTENTS
A. Chapter Competencies
B. Introduction
C. Duty Owed Guests in Hotel
Rooms
D. Duty Owed Guests and Others in
Public Areas
E. Duty Owed Guests in Restaurants
and Dining Rooms
F. Duty Owed Guests Outside
G. Duty Owed Guests in Swimming
Areas
H. Special Duties
I. Security
J. Answers to Case Example
Questions
K. Answers to End-of-Chapter
Questions
Chapter Summary
The potential liability faced by a hotel or restaurant for negligent acts encompasses virtually every part of the
facility. To avoid liability, hotels and restaurants must be diligent in maintaining their premises in a safe condi-
tion. Liability can result from unclean rooms, broken furniture, poorly maintained windows, or unsafe electri-
cal systems. Also exposing hotels and restaurants to lawsuits are uncontrolled rodents, deteriorated bathroom
appliances, unsafe elevators, broken doors, improperly maintained ceilings, dangerous steps and escalators,
slippery floors, out of control flambé dishes, and excessively hot drinks. Likewise, hospitality establishments will
be liable for failing to properly maintain sidewalks and sporting facilities on the premises and for inadequate
lighting inside and outside of the buildings.
A hotel offering swimming facilities must use reasonable care to protect the safety of guests who use these
amenities. Similarly, precautions must be taken to avoid fire and if fire does break out, to minimize injury to
guests. Security measures consistent with the foreseeable risks are required.
If a hotel chooses to offer medical services, it must ensure that the caregiver is qualified and has proper
credentials. If a guest complains of illness and expresses a need for immediate medical care, the hotel or restau-
rant should quickly call an ambulance.
A. Chapter Competencies
After studying Chapter 6, the student should be able to
1. state when hotels and restaurants are liable.
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2. list some of the areas and items in hotels and restaurants a proprietor must consider as regards to
precautions.
3. discuss some of the legal issues associated with security, fires, and medical service.
4. list at least three circumstances in guest rooms that can lead to liability if a hotel fails to exercise
reasonable care.
5. state the duty of a hotel and/or restaurant in regards to furniture and fixtures.
6. discuss the extent of liability with regards to in-room furniture and fixtures.
7. explain some of the basic procedures that can be used in hotels and restaurants to reduce the
incidents that lead to liability.
8. explain the concept of summary judgment.
9. list at least one circumstance with regard to the cleanliness of hotel rooms that can lead to poten-
tial liability.
10. list at least one circumstance with regard to beds and other furniture that can lead to potential
liability.
11. list at least one circumstance with regard to windows, window fixtures, and screens that can lead
to potential liability.
12. list at least one circumstance with regard to electrical and heating systems and equipment that can
lead to potential liability.
13. list at least one circumstance with regard to animals and insects that can lead to potential liability.
14. list at least one circumstance with regard to bathroom appliances and showers that can lead to po-
tential liability.
15. discuss the duty owed guests and others in public areas.
16. list at least one circumstance with regard to the lobby of a hotel that can lead to potential liability.
17. list at least one circumstance with regard to elevators that can lead to potential liability.
18. explain the concept of nondelegable duty with regards to elevator and/or escalator maintenance.
19. list at least one circumstance with regard to doors that can lead to potential liability.
20. list at least one circumstance with regard to hallways that can lead to potential liability.
21. list at least one circumstance with regard to stairways, steps, and their coverings that can lead to
potential liability.
22. list at least three conditions particular to restaurants that can result in injury.
23. list at least one circumstance with regard to slippery floors in restaurants that can lead to potential
liability.
24. explain the concept of constructive notice.
25. discuss the importance of enforcing a policy of frequent floor cleaning in restaurants.
26. list at least one circumstance with regard to placement of chairs and tables that can lead to poten-
tial liability.
27. define “expert witness.”
28. list at least one circumstance with regard to ceilings that can lead to potential liability.
29. list at least one circumstance with regard to flambé foods that can lead to potential liability.
30. list at least one circumstance with regard to serving hot liquids that can lead to potential liability.
31. list the conditions outside a hotel or restaurant that can lead to liability.
32. list at least one circumstance with regard to outside door service that can lead to potential liability.
33. list at least one circumstance with regard to outside grounds that can lead to potential liability.
34. list at least one circumstance with regard to ramps and parking lots that can lead to potential
liability.
35. list at least one circumstance with regard to cleanliness of hotel rooms that can lead to potential
liability.
36. list at least one circumstance with regard to outdoor sporting facilities that can lead to potential
liability.
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37. discuss the requirements pertaining to outdoor lighting.
38. list at least one circumstance with regard to outdoor lighting that can lead to potential liability.
39. list the requirements related to swimming areas.
40. list at least one circumstance with regard to swimming pool accidents that can lead to potential
liability.
41. list some of the rules that can be followed to ensure safety at swimming pools.
42. discuss the duty owed guests with regard to public water-front areas in close proximity to hotels
and resorts.
43. list at least one circumstance with regard to fire hazards that can result in liability.
44. state the concept of negligence per se in the context of fire safety equipment.
45. discuss the importance of training staff in fire safety.
46. discuss the liability to adjacent premises due to fire hazards.
47. discuss the element of forseeability in determining the duty to provide security to hotel
patrons.
48. list at least one circumstance with regards to forseeability of criminal activity that can lead to
potential liability.
49. discuss security as a “relative concept.”
50. discuss the policies with regard to security personnel and firearms.
51. explain the limitations in the requirement to offer medical services.
52. list at least one circumstance with regard to offering medical services that can lead to potential
liability.
53. List at least five preventive law tips for managers.
B. Introduction
❊Give a brief overview of the types of conduct that constitute negligence as discussed in Chapter 5.
■Stress that “The hotel or restaurant is not an insurer of guests’ safety”: This means the hotel is
not liable for all injuries that occur while guests are on the premises.
■Hotels and restaurants are liable only when they are negligent.
❊Review the doctrines that apply to negligence cases discussed in the previous chapter.
■Duty to act reasonably.
■Breach of duty.
■Injury to plaintiff.
■Proximate cause.
❊Ask the students to list the areas and items in hotels and restaurants where precautions need to be
taken. Make a list on the board or a flip chart.
■Correlate it to the students’ list.
❊Discuss the duty of reasonable care.
C. Duty Owed Guests in Hotel Rooms
❊List and explain the circumstances in guest rooms that can lead to liability if a hotel fails to exercise
reasonable care.
❊Cleanliness of hotel rooms.
■A hotel is required to use due care to have rooms thoroughly cleaned before reassignment.
❊Beds and other furniture.
■Courts have generally permitted recovery for injuries caused by defective beds and furniture.
■Hotel or restaurant must regularly inspect the furniture and discard any that is no longer
suitable. Failure to do so will result in liability.
■Emphasize, giving case examples in the text, that regular inspections for broken or defective
furniture will help reduce incidents resulting in liabilities.
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❊Windows, window fixtures, and screens.
■The same duty to inspect for defects and remedy them exists in regard to windows and screens.
■Maintaining appropriate fixtures in good condition can protect a hotel from liability.
❊Electrical and heating hazards.
■Electrical and heating devices must be maintained in good working order.
■Failure to furnish safe heating can result in an injured guest recovering damages.
❊Animals and insects.
■If a guest is injured by an animal or insect and the hotel or restaurant’s negligence led to its pres-
ence, liability will result.
■Discuss the concept of summary judgment.
❊Bathroom appliances and hot shower water.
■Stress that several cases have originated with hotel bathrooms involving defective appliances and
plumbing systems. The same rules of negligence apply.
■Discuss, using examples, the potential problems that might arise as a result of faulty water
faucets, showers, hand bars, and grips.
■Stress the fact that routine inspections can save the hotel from liability.
■Proper maintenance of a bathroom requires inspection and repairs of hand railings and other grip
devices. Lack of attention to these mechanisms can result in liability.
■Explain that bathroom doors can create problems if their maintenance is overlooked. Broken
hinges can cause a door to fall on a patron. Broken latches or locks can result in accidents.
■Discuss some of the potential problems with in-room hot tubs and whirlpools.
D. Duty Owed Guests and Others in Public Areas
❊List the public areas in a hotel and restaurant.
❊Lobby.
■Need to take special precautions.
■Rigorous inspection and maintenance procedures must be followed.
❊Elevators.
■Elevators are an indispensable part of most hotels.
■A hotelkeeper who operates an elevator is obligated to use at least ordinary care in its mainte-
nance and operation.
■Businesses with elevators should ensure that their maintenance programs include regular clean-
ing of the system components.
■Freight elevators are customarily maintained at a lower level than are elevators used by guests,
leading to added risks.
❊Doors.
■The duty of restauranteurs and innkeepers to exercise reasonable, ordinary due care to keep the
premises reasonably safe also applies to doors.
■Under ordinary circumstances, hotels and restaurants need not have a door attendant; however,
if they are aware that an extraordinary crowd will be gathering, a duty exists to employ an at-
tendant to ensure the safety of patrons entering and leaving.
❊Hallways.
■Hallways are often heavily traveled.
■Managers should inspect hallways to ensure they are properly cleaned, warning signs are utilized
during repairs and cleaning, and rugs are free from holes.
■Discuss the circumstances that might lead to accidents in hallways.
❊Stairways, steps, and their coverings.
■Guests are entitled to assume that steps and passageways are clear of dangerous impediments and
are otherwise reasonably safe.
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■Discuss what hotel and restaurant proprietors must do to avoid liability.
■Explain that building codes provide numerous safety specifications for stairways. Deviations that
result in injury to guests will likely result in liability.
■Poor construction of steps can result in liability.
■Discuss the problem of stairs of unusual heights.
■Stress that, like other steps, the movable variety must also comply with relevant safety codes and
be properly maintained.
E. Duty Owed Guests in Restaurants and Dining Rooms
❊Describe the various conditions that can result in an injury in a restaurant or dining room.
❊Slippery floors.
■Highly polished and waxed floors are the cause of many slippery-floor cases.
■Before wax or polish is applied to a floor, be sure the type being used is appropriate for the
particular floor and be certain it is applied consistently with the directions that accompany the
product.
■Some floor materials are inherently slippery, such as marble. Use of these materials does not cre-
ate liability.
❊Foreign substances on floors.
■Explain that many slippery-floor accidents in a dining room, restaurant, or snack bar result from
a foreign substance on the floor.
■Where an unsafe condition is reoccurring, the restaurant is on notice.
■Explain that, even if the existence of an unsafe condition is known to the restaurant, if the cir-
cumstance is open and obvious and customers can be expected to observe the condition and take
precautions, the restaurant will not be liable.
■Explain the term “constructive notice.”
•A restaurant or hotel has constructive notice of a problem when the condition has existed for
a sufficiently long period of time, such that the facility should have discovered the problem in
the ordinary course of monitoring the premises.
•How long is long enough? There is no definitive time period.
❊Importance of enforcing a policy of frequent floor cleaning.
■A restaurant may be able to establish that it exercised reasonable care and thus was not negligent
where it enforces a policy of frequent inspections of the floor to ensure it is free from spilled foods
or beverages.
■To help avoid liability, hospitality facilities should develop floor maintenance policies designed
to achieve floors that are safe for customers’ use. Where a restaurant has a policy of floor-cleaning
procedures that ensures safe, nonslippery floors, but the restaurant fails to adhere to that policy,
an inference may be drawn that the restaurant was negligent.
■Explain that if tables in a dining room are so close together that walking between them is dif-
ficult, a diner may foreseeably be injured. While exceeding the maximum number of diners
that can comfortably be accommodated in a restaurant may be appealing from a profit van-
tage point, it can lead to damages that easily negate any additional money the extra diners
might generate.
❊Hanging mirrors in dining rooms.
■Large plate-glass mirrors in a dining room are another factor that can cause injury.
■A restaurant must be vigilant to ensure such mirrors remain securely attached.
❊Ceilings.
■Improperly built or supported ceilings are another condition that can cause significant injuries
and give rise to liability.
❊Menu boards on ledges.
■Restaurants are well-advised not to place items on ledges near tables where customers sit.
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❊Hanging television sets.
■Sports bars and some restaurants display televisions for patrons’ entertainment.
❊Serving flambé foods.
■Flambé foods create elements of excitement but also add an element of danger and must be han-
dled with great care.
■A restaurant that serves flambé dishes or does any type of tableside cooking with a flame must
carefully train its employees on how to prepare the food safely, how to use the related cooking
devices, and what to do in the event of a fire.
❊Serving hot liquids.
■Given that we all expect tea and coffee to be served hot, the question becomes how hot is too hot?
■Industry standards: The coffee industry has determined that the optimum temperature needed
to release the flavor from coffee beans is 170 to 175 degrees Fahrenheit. This standard has been
accepted by the restaurant industry and is the temperature at which customers anticipate receiv-
ing their coffee.
F. Duty Owed Guests Outside
❊Outside door service.
■A hotel or restaurant is not, absent foreseeably rowdy circumstances, required to furnish door
attendants or valets. If it does, however, the hotel or restaurant may be liable if these employees
are negligent.
❊Grounds.
■When invitees use the sidewalk of a hotel or restaurant, they have the responsibility to exercise
care where they walk. If they trip and fall due to an obvious obstruction or defect, the hotel or
restaurant will not be responsible.
■If, however, a defect is not obvious to patrons and the restauranteur is aware of the problem, the
restaurant will be liable.
■Another pavement problem is the occasional step located in an unexpected place. Unsuspecting
pedestrians may fail to see the step and trip unless its existence is highlighted in some way.
■Holes in sidewalks.
•Often sidewalks and paved areas deteriorate over time. Numerous cases result from guests trip-
ping on depressions in walkways or uneven sidewalk slabs. The law in many states allows some
tolerance of such defects, calling small depressions too trivial to give rise to liability.
•In summary, where a patron falls on a hole in the pavement, the size of the hole and the law
of the particular state in which the fall occurred will determine whether the facility can avoid
liability. An advisable practice for hotels and restaurants is to repair pavement problems when
they first appear to avoid injury to guests. If, however, an accident occurs and a lawsuit is com-
menced, the facility should measure the depression and consider if a defense of triviality might
be availing.
■Ramps and parking lots.
•If obstructions such as stones, woodchips, or debris are found, they should be removed im-
mediately. Cracks and holes should be repaired. Other unsafe conditions should be eliminated.
❊Outdoor sporting facilities.
■Even in states that continue to follow the rule of assumption of risk, a guest does not assume the
risk that the resort will fail to maintain the sporting facility in a condition that makes it reason-
ably safe for the guest. Such failure on the part of the hotel will result in liability.
❊Outdoor lighting requirements.
■Explain the influence of the high cost of energy on lighting. An attempt to save a few dollars on
lighting can lead to a guest’s injury and liability.
■Outdoor light fixtures should be inspected daily. If they are not in good working order, they
should be repaired without delay.
■Reset electronic controls when daylight savings time begins and ends.
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G. Duty Owed Guests in Swimming Areas
❊Swimming pools help to attract business, but they have high maintenance, energy, and labor costs
and expose the hotel to another area of potential liability.
❊Accidents can be caused by wet floors, unsafe diving boards, inadequate safety equipment, horse-
play, inadequate supervision, and a variety of other factors.
❊Exercise reasonable care.
■A hotel is not an insurer of guests’ safety in and around a hotel pool. The hotel is only liable if
it fails to exercise reasonable care.
■A hotel needs to monitor carefully the use of its swimming pool to ensure safety precautions are
taken.
■If the hotel can anticipate high use of the pool, sufficient lifeguards are important.
■Rules concerning maximum capacity should be developed and honored.
■A rule should be adopted and followed requiring closing the pool when the water’s clarity is
compromised.
■Safety devices, such as the presence of a rope delineating the shallow and deep ends, should be
in good working order whenever the pool is being used.
❊Remove hazards.
■A hotel may be liable for leaving maintenance equipment in the vicinity of the pool.
❊Comply with statutory requirements.
■Failure to comply with safety requirements imposed by statutes on pool operators can result in
liability under the doctrine of negligence per se.
•Diving boards: Local governments often issue regulations applicable to pool diving boards.
Failure to comply with these laws can lead to terrible consequences for both a patron who is
injured and for the hotel.
•To avoid risks associated with diving boards and pool slides, many hotels have eliminated them.
❊Safety equipment.
■If a hotel or restaurant is uncertain as to the meaning of a statute, clarification should be sought
from an appropriate source such as the director of the governmental department responsible for
enforcing the particular law, or the hotel’s attorney.
❊Control boisterous conduct of guests.
■When boisterous conduct and horseplay are allowed in a pool area, accidents may occur.
■If there is horseplay in the pool, the hotel could be liable to the plaintiff for failing to halt the
disorderly conduct.
❊Inspect for glass in pool area.
■Glass and other debris in swimming and wading areas pose a significant risk to pool users.
❊Waterfront properties.
■These bodies of water present numerous potential dangers that can and do cause injury and
death. The risks include heavy surf, riptides, underwater tows, and man-eating animals. In the
cases that result from those related deaths or injuries, the plaintiffs argue that the hotel breached
a duty to warn of risks and protect guests from them. Most cases hold that hotels, which neither
own nor control the ocean, have no duty to warn, correct, or safeguard guests from naturally
occurring, even if hidden, dangers common to waters.
■Off-premise beaches.
•Given that a goal of hospitality facilities is not just to avoid liability, but also to protect guests’
well-being and provide a fun, healthy getaway, a hotel near a beach should keep apprised of
related risks and alert their patrons to danger.
•A minority of states require a hotel to warn of risks at off-premises facilities that the innkeeper
reasonably can foresee that guests will visit.
■Waterfront risks created by a hotel.
•If a hotel with waterfront property erects an entertainment facility for guests utilizing the
water, it must warn of any related risks and prohibit inappropriate use.
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■Restrict use or warn of hazards in the water.
■Inspect lake bottoms for hazards.
•If a hotel invites its guests to swim in a natural body of water, the inn’s duty of reasonable
care requires it to inspect the bottom for dangerous objects and, if any are found, remove
them.
•The facility should also prevent the source of the dangerous objects, such as boats, from us-
ing the swimming area.
•Access to the water: If provided, the duty of care owed to guests includes maintaining any
such walkway, bridge, or boardwalk between the hotel and the water front in a reasonably
safe condition.
H. Special Duties
❊Injuries caused by fire.
■Maintain fire safety equipment.
•Most states and many localities have passed statutes and building codes listing equipment that
all hotels and restaurants are required to have for fire protection. Failure to provide the man-
dated equipment constitutes negligence per se, resulting in automatic liability.
•To accommodate guests who are hearing impaired, alarm systems should include a visual com-
ponent.
•Failure to provide required fire safety devices can lead to liability.
•Remember, compliance with statutory safety requirements does not guarantee freedom from
liability. Rather, these laws set only the minimum standards for fire safety.
•Explain the role of the fire marshal.
■Train staff how to respond to a fire.
■Liability to adjacent premises.
•Neighboring properties are at risk. If the business where the fire originated was negligent in
causing the blaze, that business may be liable to the owner of an abutting property that is dam-
aged by the fire.
I. Security
❊Personal injury, loss of life, and loss of property suffered as the result of criminal activity has cost
the hospitality industry many millions of dollars in damage payments.
❊Any business that invites the public onto its premises must take reasonable steps to guard against
the risk of assaultive behavior. Nevertheless, this duty does not extend to unforeseeable or unex-
pected criminal acts by third persons.
■Thus, a business with reason to anticipate the occurrence of a criminal act has a duty to protect
patrons. A business is charged with knowing criminal activity will occur where the perpetrator,
prior to the criminal act, was abusive or disorderly, or where there existed a pattern of prior crim-
inal activity that made similar or related conduct foreseeable.
❊Foreseeability of criminal activity.
■Foreseeability is an important element in determining whether a hospitality defendant had a duty
to protect patrons from criminal acts of third parties.
■If the facility is in a high-crime area, or if the facility or its customers have been the victim of
criminal activity, the restaurant or hotel should, for the purpose of defining its legal duty, antic-
ipate additional criminal activity.
■The duty to anticipate criminal activity and provide against it may be triggered by even one or a
few prior incidents.
■If an attack occurs unexpectedly with no reason to anticipate it, the facility owes no duty to the
patron to offer protection against the incident.
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❊Matching security to circumstances.
■Explain that reasonable care is the duty of care required by an innkeeper for guests’ safety. It
is not a static, clearly defined concept. One definition will not fit all hotels in all locations at
all times.
■Discuss the basic measures to secure guest rooms.
❊Adequate security can eliminate liability.
■If a hotel or restaurant takes adequate security precautions and a guest is nonetheless attacked,
the facility will not be liable.
❊Security personnel and firearms.
■Should security personnel in a hotel carry weapons? Discuss the answer.
❊A hotel is not required to offer its guests medical services. To avoid potential liability if a doctor
malpractices, most hotels today will not recommend a particular doctor. Instead, the hotel might
provide a list of available physicians and require the guest to select.
❊Sometimes hotel staff may try to diagnose a guest’s problem and suggest home remedies. Person-
nel should be trained not to do this. A guest whose injury is made worse by such advice may sue
and is likely to win.
J. Answers to Case Example Questions
6-1-1. What is meant by the following statement in the beginning of the eighth paragraph: “An
innkeeper in Oklahoma continues to have a status-based, common-law duty of care to
a guest”?
It means that even though there are different statutes governing “duty of care,” the common-law
duty of care to a guest still applies. That is, this duty remains unaltered by inspection and licens-
ing statutes enacted under the police power of the state. The owner or operator of a motel is not
an insurer of his guests’ personal safety. Often described as a duty to maintain the premises in a
reasonably safe and suitable condition, the innkeeper’s common-law responsibility applies only to
defects or conditions that are in the nature of hidden dangers, traps, snares, pitfalls, and the like—
things that are not readily observable. The duty is fulfilled when reasonable care is taken to pre-
vent the invitee’s exposure to dangers, which are more or less hidden, not obvious.
6-1-2. What facts presented in the case might establish that the hotel used reasonable care to
keep spiders and insects out of the hotel?
The facts that reasonable care was used were:
•Copies of monthly invoices from Admiral Pest Control Co. (“Admiral”) showing a contin-
uous program of pest control services, including the time period in which Copeland suf-
fered her injury.
•Andrews, who was the Days Inn manager at the time of Copeland’s injury, testified that
she was trained in motel management, including pest control; she had engaged Admiral to
spray the motel premises for insects and other pests; she had given Admiral oral instruc-
tions that all pests were to be eliminated from the property; she sometimes personally
watched as the pest control chemical was applied; she had terminated the services of the
previous extermination company because it had failed to eradicate a roach infestation; she
had never had to call Admiral because of a problem with any type of spider; and she had
never received any complaints from customers other than Copeland about the presence of
spiders.
•On Monday or Tuesday morning after Copeland’s incident the previous Wednesday, Andrews
and Admiral’s exterminator searched for spiders in the room in which Copeland had stayed
as well as several other rooms. Although no spiders were found, they nonetheless sprayed the
rooms.
•The Days Inn received two or three annual, unannounced inspections by the Oklahoma
Department of Health and had not been cited for any deficiencies during Andrew’s tenure
as manager.
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