Hare Krishna Roswell Hotel, LLCv.Corsino
An imposter used a copy of Sharon Corsino’s driver’s license and another man’s debit card to book a Studio 6 room through a third-party site, then made fraudulent purchases. Police matched the license photo to hotel video and arrested Corsino; prosecutors dropped the charges after determining she was not the woman in the video. Corsino sued the hotel, alleging negligent check-in procedures caused her arrest and related losses. The Court of Appeals reversed the denial of summary judgment. It held that Georgia law recognizes no general duty to protect everyone from unreasonable risk; the hotel’s brand manual did not create a duty to third parties, and it required only that identification match the reservation name for third-party bookings. Because the imposter’s license matched Corsino’s reservation and a payment card was not required at check-in, the hotel did not violate that procedure. Restatement (Second) of Torts § 324A also did not apply: Corsino alleged no physical injury, and the hotel’s conduct did not increase her risk. With no statutory or common-law duty, her negligence claims failed; the court did not reach the hotel’s separate argument that Corsino’s failure to update her address with Georgia’s Department of Driver Services caused the misuse.
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