This article is written by Ashish Singh, a first-year law student pursuing B.A. LL.B. from LCIT College of Commerce and Science, 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, asking him to cook them. The chef prepared the dish and sent it to the plaintiff’s room with an additional bill of $1. The plaintiff refused to pay the bill, claiming that the charge was excessive. That same evening, he dined at the hotel café, and when the staff again asked him to sign for the extra service, he declined again.
The next morning, Sunday, when he arrived at the breakfast table, the waiter refused to serve him because he had refused to pay the $1 bill. The management of the hotel, however, made this announcement publicly in the presence of other hotel guests. 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 may legally refuse to host a guest who has declined 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, 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.
If the café staff wrongfully ejected the plaintiff, he could recover damages for the humiliation that injured his feelings, but the case certainly did not involve his reputation as a faultfinder. 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:
The court initially held that it would deny the plaintiff damages for the insult of the innkeeper ejecting him from a public dining room, because other innkeepers considered him an undesirable guest.
But The judgement was later reversed and the plaintiff was compensated.
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