## Facts

- Harry C. Adams traveled as a paying cabin passenger on the New Jersey Steamboat Company’s overnight steamer from New York to Albany.
- Adams carried $160 for travel expenses to his ultimate destination.
- The company assigned Adams a stateroom in exchange for the usual charge.
- Before sleeping, Adams placed the money in clothing left in the stateroom, locked the door, and fastened the windows.
- During the night, the money was stolen from the stateroom, apparently by someone reaching in through a window.
- A jury found (1) Adams was the defendant’s passenger, (2) Adams was not negligent, and (3) $160 was a reasonable amount to carry for travel expenses.
- The trial court instructed that the carrier would be liable for the loss as a matter of law without proof of negligence; the jury awarded Adams $160, and the judgment was affirmed on intermediate appeal.

## Issues

1. Whether an overnight steamboat company providing stateroom accommodations is liable without proof of negligence for theft of a reasonable sum of a passenger’s money from a locked stateroom.

## Decision

- The Court of Appeals affirmed the judgment for Adams.
- The court held the steamboat company liable for the theft without requiring proof of negligence.
- The court treated the relationship between an overnight steamboat and its stateroom passengers as materially equivalent to that of an innkeeper and guest for purposes of liability for theft of guests’ property within reasonable limits.

## Legal Principles

- A carrier that provides stateroom lodging to passengers may be subject to innkeeper-style, insurer-like liability for theft of guests’ property, even absent negligence.
- A reasonable amount of money carried for travel expenses is recoverable when stolen from a passenger’s assigned accommodation, where the passenger is not negligent.
- The stricter rule applicable to innkeepers and analogous lodging providers may apply rather than the ordinary-care approach used in some sleeping-car contexts.

## Conclusion

An overnight steamboat company furnishing stateroom accommodations is liable without proof of negligence for theft of a passenger’s reasonable travel money from the passenger’s locked stateroom, based on the innkeeper-guest analogy and related public-policy considerations.


Adams v. New Jersey Steamboat Co., 151 N.Y. 163, 45 N.E. 369 (N.Y. 1896)