Rarrick v. Browne

At common law, an innkeeper’s liability for loss of a guest’s property is analogous to that of a common carrier. He is an insurer of such property against all loss on his premises with the following exceptions:

1. Loss occasioned by act of Hod or of the public enemy.

2. Loss occasioned by negligence of the guest.

3. Loss occurring while the property is in the exclusive custody and control of the guest (for example, where not kept in the guest’s room or other proper place designated by the innkeeper for safekeeping of such property).

Thus, it is usually sufficient for the guest to prove that the…