Westin Operator, LLC, Petitioner v. Jillian Groh

Summary

The court held that a hotel has a duty, arising from the innkeeper-guest relationship, to exercise reasonable care when lawfully evicting a guest, including refraining from ejecting an intoxicated guest into a foreseeably dangerous environment. Because genuine factual disputes remained concerning the circumstances of the eviction, summary judgment was improper on the negligence and negligent hiring and training claims. The court also held that the Dram Shop Act did not apply because the hotel did not serve or provide alcohol.