A bride and groom meticulously planned a wedding at the Deauville Hotel in Miami. Alas, the anticipated reception did not go as planned. Instead, nine days before the big event, the city of Miami Beach red-tagged (shut down) the hotel’s three ballrooms as “unsafe” and in violation of building codes.
The hotel attempted to work with the city to reopen the ballrooms. First, it requested a 90-day reprieve to enable it to address the issues raised. The city building inspector, responsible for the health and safety of the public, was not having it. The hotel then requested and was granted an emergency inspection on the day of the wedding. Repairs were not completed and so the ballrooms remained closed.
The hotel unilaterally moved the wedding reception to the lobby. The couple was not informed of the problem until a few hours before their nuptials.
Besides the obvious lack of privacy, the lobby was too small for the 190 guests. Tables were “crammed” together. Hotel guests walked through the reception, some in their bathing suits. The disc jockey was repeatedly told to lower the volume. Per the bride and groom, their wedding was “ruined,” a “public spectacle” and “cramped and very uncomfortable.” The bride was “embarrassed, cried uncontrollably, and experienced nightmares.” Yikes!
Predictably, the couple sued. They had paid the hotel $13,000 and they wanted compensation. The plaintiffs wisely opted for a jury trial. The jurors awarded them $30,500. This included the $13,000 paid by the couple, plus expenses for flowers, linens, photography, videography, entertainment, transportation and cake, totaling $9,500. The jurors added more to the verdict, likely motivated by sympathy and ire.
The Deauville appealed. In the end, the couple walked away with the $13,000 they paid for their reception but no more. The court noted two fundamental principles relating to damages for breach of contract. First, a plaintiff is not entitled to recover compensatory damages in excess of the amount of loss “actually inflicted by the action of the defendant.”
Second, the purpose of compensatory damages is to reimburse the plaintiff for a loss, “not to punish defendants or bestow a windfall on plaintiffs.”
Hotels have a duty to their guests to maintain their premises in a safe and sanitary condition. The reason is not only to prevent injury and illness, but also to avoid collateral damage, including disappointing guests who host affairs at their facilities.
Karen Morris is a lawyer, municipal judge and Distinguished Professor at Monroe Community College in Rochester, N.Y., where she teaches hospitality law.