This article is written by Ashish Singh, a first-year law student pursuing B.A. LL.B. from LCIT College of Commerce and Sciences, Bilaspur.
Title of Case: Morningstar v. Lafayette Hotel Co.
Citation: 211 N.Y. 465, 105 N.E. 656 (N.Y. 1914)
Court: Court of Appeals of the State of New York
Parties:
Petitioner: William Morningstar
Respondent: Lafayette Hotel Company
Facts of the case:
The plaintiff was a guest at the Lafayette Hotel in the city of Buffalo. He went out of the hotel and purchased some spareribs. He then presented them to the hotel chef with a request that they be cooked for him. The chef prepared the dish and sent it to the plaintiff’s room. But with an additional bill of $1. The plaintiff refused to pay the bill. He claimed that the charge was excessive. That same evening, he dined at the café of the hotel, and was again asked to sign for the extra service. He declined again.
The next morning, Sunday, when he presented himself at the breakfast table, he was refused to be served as he had refused to pay the $1 bill. This was however an announcement made publicly, in the presence of other guests of the hotel. The plaintiff stayed at the hotel till Tuesday, taking his meals elsewhere and then he left.
Issues:
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- Whether the charge in controversy was excessive
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- Whether the defendant’s conduct had injured plaintiff’s reputation.
Justifications:
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- If the charge was a reasonable one, the defendant had a right to refuse to serve the plaintiff further, and that if it was not, the refusal was wrongful.
In this, there was no error. An innkeeper is not required to entertain a guest who has refused to pay a lawful charge. Whether the charge in controversy was excessive, was a question for the jury.
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- The plaintiff said, however, that there was error in the admission of evidence which eliminates the verdict, he alleged in his complaint that the defendant’s conduct had injured his reputation.
The plaintiff offered no proof on that head, but the defendant took advantage of the allegation to prove what the plaintiff’s reputation was. A number of hotel proprietors were called as witnesses by the defendant, and under objection were allowed to prove that, in their respective hotels, the plaintiff’s reputation was that of a chronic faultfinder. Some of them were permitted to say that the plaintiff was known as a “kicker.” Others were permitted to say that his reputation was bad, not in respect of any moral qualities, but as the guest of a hotel.
The plaintiff, if wrongfully ejected from the café, was entitled to recover damages for injury to his feelings as a result of the humiliation, but his reputation as a faultfinder was certainly not at issue. The damages recoverable for such a wrong were no less because the occupants of other hotels were of the opinion that he complained too freely.
Judgement:
It was first held that, the plaintiff was to be refused damages for the insult of being put out of a public dining room because other innkeepers considered him an undesirable guest.
But The judgement was later reversed and was in favor of the plaintiff and he was compensated.
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