Also known as: hostlers · hosteler · hostelers · innkeeper
Written by attorneys · grounded in primary & secondary sources — see below
An archaic term for a person who operates an inn or provides stabling services to travelers. The label historically encompassed both the provision of lodging and the care of horses at the same establishment.
Hugo Hart, operating a roadside inn as hostler, watched a guest slip on an icy walkway and remain on the ground for several minutes. Hugo continued checking other arrivals rather than summoning medical help or providing first aid. The guest later sued, claiming the hostler breached the duty owed to persons received as guests.
Harriet Hamilton, a hostler employing chambermaids at her historic inn, refused to pay the state-mandated minimum wage. One employee sued to recover the difference between actual pay and the required amount. The court upheld the wage order against the hostler's due-process challenge.
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Hector Hernandez, hostler at a small motel, posted a sign limiting room rentals to members of one race. Prospective guests of another race were turned away at the front desk. State law later prohibited such refusals, and the hostler faced enforcement proceedings.
Hannah Hughes, hostler of a lakeside inn, maintained a policy of refusing rooms to travelers from certain states. Congress enacted a statute prohibiting such discrimination in places of public accommodation. The hostler challenged the statute as exceeding federal power.
Hamid Hassan, hostler of a grain-elevator inn serving travelers, charged rates the state commission deemed excessive. The commission ordered a reduction. The hostler argued the order deprived him of property without due process.
Hana Huang, hostler who purchased an older inn, rented rooms without inspecting for hidden structural flaws. A guest was injured when a balcony railing collapsed. The guest sued the hostler under negligence principles applicable to landlords of residential property.
Modern courts treat a hostler as an innkeeper subject to the duties stated in Restatement (Second) of Torts § 314 A(2). The label itself is obsolete, but the underlying obligations to guests remain enforceable.
A hostler owes an affirmative duty to protect guests from unreasonable risk of harm and to render first aid once aware of injury. A landowner owes no such duty to trespassers absent special circumstances.
No. A mistaken belief that a statute permits disposal does not relieve the hostler of conversion liability when the property is clearly identifiable and unclaimed.
…As we have seen, 32 States prohibit racial discrimination in public accommodations. These laws but codify the common-law innkeeper rule which long predated the Thirteenth Amendment. It is difficult to believe that the Amendment was intended to abrogate this principle. Indeed, the opinion of the Court in the Civil…