Arlington Hotel Co. v. Fant

Background

Three guests of the Arlington Hotel sued the hotel company after a fire destroyed their personal property. The hotel sat on a small tract in Hot Springs that Arkansas ceded to the United States, and Congress accepted that cession in 1904. The guests said the ceded land was under exclusive federal control so the Arkansas 1913 law relieving innkeepers of fire liability unless negligent did not apply. Lower courts heard the cases, a jury returned verdicts for the guests, and the state courts’ rulings were brought up for review.

Reasoning

The core question was whether the United States validly held exclusive authority over the small ceded tract around the springs and hospital. The Court reviewed the long legislative history — the 1832 reservation of the springs, subdivision and reservation acts, the 1882 appropriation for an Army and Navy hospital, Arkansas’s 1903 cession, and Congress’s 1904 acceptance and later naming of the area a national park. Relying on earlier decisions about state cessions and federal control for national purposes, the Court concluded the federal government could hold exclusive control of the tract to secure the springs and hospital, and that Arkansas’s 1913 law did not apply there.

Real world impact

Because the ceded tract is treated as under federal control, hotel guests on that land remain protected by the old common-law rule and may recover for fire losses despite the state statute. The decision confirms federal authority over the specific Hot Springs tract while leaving broader questions about other parks open.