Massachusetts Court Says Motel Staff Not Liable for Guest’s Suicide

CHICOPEE, Mass. — A Massachusetts court’s decision Thursday that absolved a motel chain from blame for the suicide of a guest clarifies the hospitality industry’s duty of care to its customers.

The man’s family sued but Motel 6 successfully argued it had no reason to know the guest, Michael Bonafini, was suicidal.

The Massachusetts appellate court said the transitory nature of hotel stays and limited interactions of guests with staff means the proprietors have a reduced duty of care compared to other organizations, such as hospitals, jails or universities.

Bonafini’s family said the motel staff in Chicopee should have been more proactive in protecting the man from self-harm.

He made statements during a phone call from the motel to his relatives that made them concerned for his welfare. When his wife and mother went there to check on him, two staff members refused to give them his room number.

Instead, they called the room. The first time, Bonafini said he did not want to be disturbed. The second time, he hung up on them.

On the third day of Bonafini’s stay at the motel, Bonafini did not check out by the noon check-out time. When the manager entered the room, she found the man had hanged himself to death.

His family argued in their wrongful death lawsuit that the staff should have called the police to do a welfare check on Bonafini when his relatives told them about their concerns for him.

The Massachusetts Appeals Court disagreed in its written opinion.

“Although we recognize that the defendants were informed by Bonafini’s family of their concerns for him, this –- without more — is not enough to have triggered a duty on the defendants to rescue, as tragic as the consequences of inaction were,” the opinion says.

The court acknowledged hotels and motels must protect guests from foreseeable harm.

“Innkeepers have a special relationship with their guests and, accordingly, in certain circumstances may have an affirmative duty to take reasonable steps to prevent certain kinds of harm,” the ruling says.

Bonafini’s case was different.

Before the staff could rightfully be accused of negligence, Bonafini would have needed to tell them his “plans or intentions to commit suicide,” the court said.

“Instead, all that is 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,” the court said.

The trial court had dismissed the lawsuit. The appeals court affirmed the dismissal.

The case is John F. Bonafini, personal representative, v. G6 Hospitality Property LLC et al., in the Massachusetts Appeals Court.

Tom can be reached at [email protected] or on Twitter at @tramstack.