Miller v. Strahl

Background

A hotel guest sued the owner and operator of a large Omaha hotel after being injured by smoke while trying to escape a fire on the fourth floor late at night. The guest said the hotel had more than fifty rooms and four or more stories, and that a fire started between midnight and dawn on January 23, 1911. Hotel employees smelled smoke around 1:30 a.m., and a guest alerted the night clerk, who merely looked into a cuspidor. Two hours later the halls were full of smoke. The guest could not get the elevator, did not know where the stairs were, tried a rope fire escape that failed, and was hurt. A jury awarded the guest $6,500 and the state supreme court affirmed.

Reasoning

The Court reviewed a Nebraska law that requires large hotels to employ a competent night watchman from 9 p.m. to 6 a.m., place an alarm gong on each floor, awake and warn guests in case of fire, and “do all in their power” to save guests. The hotel owner argued the law was vague, violated due process by forcing employees to risk their lives, and unlawfully discriminated by applying only to bigger hotels. The Court rejected these arguments, saying a hotelkeeper who runs a hotel takes on those duties and the statute reasonably sets general obligations tailored to circumstances. The Court found evidence the owner and staff failed to investigate early warnings and did not give notice, so liability and the damages award were proper.

Real world impact

This ruling affirms that states can require large hotels to keep night watchmen, alarms, and to warn and assist guests during fires. Hotel owners who fail to follow those duties can be held liable for guest injuries. The decision upholds the statute against challenges about vagueness and unequal treatment.