Title 29: Hotels

Section 1: Legal Paraphrase

N.J.S.A. Title 29, "Hotels," is a compact statutory title governing lodging establishments — hotels, rooming houses, and tourist houses and camps. It has two core functions. First, it codifies innkeeper regulation: Chapter 2 defines "hotel" (N.J.S.A. 29:2-1), limits an innkeeper's liability for guests' valuables where a safe depository and posted notice are provided (N.J.S.A. 29:2-2), and sets standards of care for guests' property (N.J.S.A. 29:2-3, 29:2-4). Second, it addresses health, safety, and registration: Chapter 1 historically imposed fire-safety mandates on rooming houses (now largely repealed; see N.J.S.A. 29:1-44), Chapter 3 governs hotel-name registration, and Chapter 4 requires guest registers at tourist camps, homes, rooming houses, inns, and hotels, mandates posted rates, and, in modern amendments, protects hotel employees through panic-device and service-disruption provisions (N.J.S.A. 29:4-9 to 29:4-15). Municipal licensing supplements these state standards.

Section 2: ELI-10 Explanation

Title 29 is the rulebook for places where people sleep away from home — hotels, motels, rooming houses, and tourist homes. It keeps guests safe and makes the rules fair for everyone. One part says that if a hotel gives you a safe for your money, jewels, and furs, and posts a sign telling you to use it, you should — if you leave your fancy coat on the bed and it disappears, the hotel usually does not have to pay. Another part says rooming places must keep a list of who is staying there and show the price list so nobody is surprised by the bill. The law also says hotels must put panic buttons in housekeeping rooms so workers can call for help. Think of it as the "rules for sleepover places" law — it protects guests, owners, and workers.

Section 3: General Application & Case Example 1

How It Is Applied

In practice, Title 29 operates at the intersection of state innkeeper law and the local police power over lodging. Chapter 2 governs the daily contractual relationship between hotel and guest: the safe-deposit scheme and liability limits apply automatically whenever a hotel provides a depository and posts the required notice, and courts construe those provisions strictly against the hotel. Chapters 3 and 4 impose administrative duties — hotel-name registration with the Secretary of State, mandatory guest registers at tourist camps, tourist homes, rooming houses, inns, and hotels (with misdemeanor penalties for violations), and posted rate schedules. Historically, Chapter 1's fire-safety mandates — fire alarms and "smoking in bed prohibited" signs — set the state's standard for rooming houses; although Chapter 1 has since been repealed (N.J.S.A. 29:1-44), courts treated such health-and-safety regulation of lodging as a valid exercise of the police power, and municipalities continue to license and inspect rooming houses under their own ordinances. Modern amendments (N.J.S.A. 29:4-9 et seq.) add panic-device and service-notice duties on hotel employers.

Case Example

• Case Name & Citation: Gilman v. Newark, 73 N.J. Super. 562 (Law Div. 1962)
• Statute Applied: N.J.S.A. 29:1-25 and 29:1-26
• Brief Summary: Rooming-house owners challenged Newark's 1961 ordinance licensing rooming houses and requiring fire-alarm systems, self-closing fire doors, and "smoking in bed prohibited" signs, arguing it was arbitrary, discriminatory, and confiscatory. The Law Division upheld the ordinance, reasoning that fire precautions serve public safety and that Title 29's own state standards — N.J.S.A. 29:1-25 and 26, which require "an even more elaborate" fire-alarm system for hotels — showed that comparable local demands on rooming houses were reasonable exercises of the police power. The court struck down only one provision (barring minors from rooming houses) as unreasonable, applying severability so the licensing and fire-safety scheme survived intact.
• Source Link: https://scholar.google.com/scholar_case?case=15125075645186883500

Section 4: ELI-10 Application & Case Example 2

Real World Example (Explained Simply)

Imagine you check into a hotel for vacation carrying your grandmother's fancy fur coat. The hotel keeps a big safe in the office, and a sign on your door says: "We have a safe for your money, jewels, and furs — please put them there." You leave the coat on the bed instead, and when you come back it is gone. Under N.J.S.A. 29:2-2 — Title 29's rule — the hotel warned you and gave you a safe place, so the hotel usually does not have to pay for the coat. The law makes a deal: hotels that do their part (safe plus a clear sign) are protected from big claims, while guests who ignore the warning bear the loss themselves. But if the hotel claims to have a safe and really does not, or hides the sign, the hotel stays responsible. The rule rewards honesty and punishes carelessness — on both sides.

Case Example

• Case Name & Citation: Platt v. New Irvington Hotel of Lakewood, Inc., 85 N.J. Super. 330 (App. Div. 1964)
• Statute Applied: N.J.S.A. 29:2-2
• Brief Summary: A hotel guest sued after her mink coat disappeared from her room, and the hotel invoked the exculpatory scheme of N.J.S.A. 29:2-2, showing it provided a safe and had posted an 8¾-by-7½-inch notice on the guest-room bathroom door quoting the statute. The Appellate Division held the notice was conspicuous as a matter of law and that the guest's failure to deposit the coat was her own neglect. But it found a genuine factual dispute over whether the hotel actually maintained a suitable, secure depository for furs, so it remanded for trial on that single issue, directing that judgment for the hotel would follow if a suitable depository existed.
• Source Link: https://scholar.google.com/scholar_case?case=9088087587537210676