Special Relationship between Innkeepers and Guests 


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By: Sean P. Kelly

The Massachusetts Appeals Court recently considered, in a matter of first impression, whether “innkeepers” have a duty to prevent their guests from committing suicide.  In Bonafini v. G6 Hospitality Property, LLC, the Appeals Court concluded there is no duty, in this case, for the innkeeper to take preventative steps.  In reaching this conclusion, the Appeals Court noted specific cases that illustrated the special relationship between an innkeeper and its guests including an innkeepers’ duty to maintain an adequate security system, a duty to take reasonable care of the premises, a duty to take reasonable steps to protect a guest from assault by another guest, and a duty to take reasonable steps to protect guests from fire set by arsonist. 

Likewise, the Appeals Court acknowledged that the Massachusetts Supreme Judicial Court has established a duty to prevent suicide in other special relationship circumstances, including a university-student, hospital-patient, and jailor-prisoner setting.  However, in Bonafini, the Appeals Court reasoned that, unlike in those relationships, that “have a custodial quality, involve a form of dependency or protection, and are of longer duration than is typical of hotel guests” there is not necessarily such relationship between the innkeeper and its guests.  Moreover, the Court noted that it “need not decide whether an innkeeper-guest relationship falls within one of these limited circumstances because, even if it does, the duty would not arise under the facts alleged here.”  

In Bonafini, all that was alleged “is that Bonafini’s mother and wife informed motel employees that Bonafini was at risk of suicide, and asked for his room number so they could assist him.”  This alone “is not enough to have triggered a duty on the defendants to rescue, as tragic as the consequences of inaction were.” 

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Note: if you or someone you know is in crisis, call 988 for the Suicide & Crisis Lifeline.