Where a trunk filled with goods for sale was left by an expressman on the sidewalk in the usual place in front of the inn and the expressman's check was given to the clerk, the innkeeper was held not liable ; Becker v. Haynes, 29 Fed. 441; so of a stock of jewel ry left with an attendant in the coat room ; Elcox v. Hill, 98 U. S. 218, 25 L. Ed. 103 ; and of a package containing a gold locket of the value of $221 banded to the clerk with out any information as to its contents; Hor ton v. Arcade Co., 114 Mo. App. 357, 89 S. W. 363.
Under the New York statute an innkeeper was held not liable for $50 stolen from un der the guest's pillow while asleep ; but was liable for a valuable watch ; Ramaley v. Leland, 43 N. Y. 539, 3 Am. Rep. 728 ; see also Becker v. Warner, 90 Hun 187, 35 N. Y. Supp. 739 ; and for a gold watch and silver forks and a silver soup ladle stolen from a guest's trunk ; Briggs v. Todd, 28 Misc. 208, 59 N. Y. Supp. 23. But in Rains v. Maxwell House Co., 112 Tenn. 219, 79 S. W. 114, 64 L. R. A. 470, 2 Ann. Cas. 488, the statute was held to apply to a watch. Money necessary
for travelling expenses ($90) and a watch were held not within the statute ; Maltby v. Chapman, 25 Md. 310. If the innkeeper is shown to have been negligent he is liable to the full value of the goods ; [1891] 2 Q. B. 11; otherwise under the English statute, only for their value up to £30.
The act does not apply where a guest had packed her goods to leave the hotel and de livered them to the hotel porter sent to re ceive them ; Rockhill v. Hotel Co., 237 111. 98, 86 N. E. 740, 22 L. R. A. (N. S.) 576 ; nor where the loss of goods is due to the negligence of the innkeeper's servant ; id.
It has been held that a hotelkeeper, in whose safe a boarder deposits money for safe-keeping, is no more than a bailee, and when the money is stolen from the safe by his night clerk, is not liable therefor, in the absence of proof of want of ordinary care in employing him ; Taylor v. Downey, 104 Mich. 532, 62 N. W. 716, 29 L. R. A. 92, 53 Am. St. Rep. 472. See Beale, Innkeepers.