Adams v. . New Jersey Steamboat Co.

New York Court of Appeals
45 N.E. 369, 151 N.Y. 163, 5 E.H. Smith 163 (1896)

ELI5:

Sections

Rule of Law:

A steamboat company providing private staterooms for passengers is held to the strict liability standard of an innkeeper, making it liable as an insurer for the theft of a passenger's personal effects without proof of negligence.

Facts:

The plaintiff purchased a ticket as a cabin passenger on the defendant's steamer Drew for a trip from New York to Albany.
The plaintiff was assigned a private stateroom for the voyage and paid the usual charge.
He carried $160 in cash on his person, which was a reasonable sum for his travel expenses to his ultimate destination of St. Paul, Minnesota.
Upon retiring for the night, the plaintiff left the money in his clothing within the stateroom.
The plaintiff locked the stateroom door and fastened the windows before going to sleep.
During the night, a thief stole the money, apparently by accessing the room through the window.
The jury determined there was no negligence on the part of the plaintiff regarding the loss.

Procedural Posture:

The plaintiff sued the defendant steamboat company in the trial court to recover the stolen money.
The trial judge instructed the jury that the defendant was liable without proof of negligence.
The jury returned a verdict in favor of the plaintiff for the full amount of the loss.
The defendant appealed the judgment to the General Term (intermediate appellate court).
The General Term affirmed the judgment of the trial court.
The General Term granted the defendant leave to appeal to the Court of Appeals.

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Issue:

Is a steamboat company liable as an insurer for money stolen from a passenger's private stateroom during a voyage, without any proof of negligence on the part of the company?

Opinions:

Majority - O'Brien

Yes. The court held that the relationship between a steamboat company offering staterooms and its passengers is legally indistinguishable from that of an innkeeper and a guest. The court reasoned that a steamer is effectively a 'floating inn,' where the passenger pays for the exclusive use of a room for sleeping and protection, reposing extraordinary confidence in the carrier. Unlike railroad sleeping cars—where berths are open and the railroad is liable only for negligence—a steamboat provides private, secure accommodations identical in function to a hotel room. Therefore, public policy dictates that the strict common law liability of innkeepers (liability as an insurer) applies, rendering the defendant liable for the theft even without proof that the company was negligent.

Analysis:

This decision firmly establishes the 'floating inn' doctrine in New York law, equating the liability of maritime carriers offering private accommodations with the strict liability of hotel keepers. The court draws a sharp analytical distinction between the privacy of a steamboat stateroom and the open nature of railroad sleeping cars, confining the negligence-only standard to the latter. By grounding the decision in public policy and the nature of the contract (exclusive use vs. mere transit), the court reinforces the protection of travelers who surrender control of their safety to carriers in enclosed environments. This creates a bifurcated liability scheme for transportation providers based on the physical layout and privacy afforded to the passenger.

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