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INNKEEPER'S LIABILITY. (STATUTORY REGULA TIONS —DEFINITION OF JEWELRY.)

SUPREME COURT OF TENNESSEE. In the case of Rains v. Maxwell House Co., 79 Southwestern Reporter 114, a ques tion arose as to the liability of the proprietor of a hotel for the loss of a watch and fob which a guest had left under his pillow. The Tennessee act provides that whenever the proprietor of a hotel shall provide a safe place for the keeping of any jewels and ornaments belonging to a guest, and the guest has not deposited them, the proprietor shall not be liable for their loss, provided he has posted a notice stating the fact that a safe and con venient place in which money, jewels, orna ments, etc., may be deposited, has been pro vided. The court, after stating that the wellknown common-law rule is that an innkeeper is absolute insurer of the property of his transient guest, reviews at length the deci sions bearing upon the point in those States where the liability has been regulated by a statute similar to that in force in Tennessee. The earlier cases all hold that such statutes contemplate that a reasonable amount of money for traveling expenses and articles for personal use and convenience, although within the terms of the statute, are not to be considered as within' its spirit, and that a guest by retaining such articles in his own possession instead of depositing them with the innkeeper, does not absolve the inn keeper from his liability. The first case to overthrow this doctrine was that of Hyatt T-. Taylor, 42 X. Y. 258, in which the court held that the statute must be strictly enforced. The later case of Rosenplanter r. Rossette, 54 N. Y. 255, sustains the doctrine pro nounced in the Hyatt case, as does also the case of Stewart v. Parsons. 24 Wis. 242. The Tennessee court holds that a watch and fob must be considered as embraced in the term ''jewels and ornaments." The court says that Webster defines the word "jewel" as an omament of dress, usually made of a preci ous metal having enamel or prec;ous sfones as a part of its design. They *re of the opinion, however, that the sense in which it was used by the Legislature is the common meaning attributed to it as an ornament or

useful article of value, and embraces a watch and fob used as a timekeeper and in which precious stones may or may not form a part. If a guest sees proper to keep his watch and money upon his person, he does so at his own risk, just as he does when he keeps it upon his person and in his possession when not in the hotel. In no prior Tennessee case does this point seem to have been squarely raised. INSURANCE. (EMPLOYERS' LIABILITY—ACCIDENT —INFECTION WITH DISEASE.) MISSOURI COURT OF APPEALS

In Columbia Paper Stock Co. v. Fidelity & Casualty Co., 78 Southwestern Reporter 320, the plaintiff sued on an employers' lia bility policy reciting that one of its em ployés had recovered judgment against it for injuries from accidental blood poisoning, caused by contact with material used in its business. The question was thus raised whether kidney disease produced in a ser vant by handling infected rags in the dis charge of duties connected with her employ ment was within a policy which insured against loss from liability on account of bodily injuries accidentally suffered. The defendant's contention was that as the dis ease was produced by a known cause, it could not be accidental. After a somewhat extensive review of the authorities, the court rejects this view and holds that the disease was an accidental injury. Dezell v. Casualty Co., 75 Southwestern Reporter 1102; Love lace z: Travellers' Protective Ass'n, 126 Mo. 104, 28 Southwestern Reporter 877. 30 L. R. A. 209, 47 Am. St. Rep. 638; Isitt r. Railway Passengers' Assur. Co., 22 Queen's Bench Division, 504; Travelers' Ins. Co. v. Melick, 65 Federal Reporter 178. 12 С. С. A. 544, 27 L. R. A. 629: Peck v. Equitable, etc., Ass'n. 52 Hun. 255. 5 New York Supple ment 215; Freeman r. Mercantile, etc., Ass'n, 156 Mass. 351, 30 Northeastern Re porter 1013, 17 L. R. A. 753; McCarthy». Travelers', etc., Co.. 8 Biss. 362, Fed. Cas. No. 8682; United States etc., Ass'n r. Barry, 131 U. S. loo, 9 Supreme Court Reporter 755, 33 L. Ed. 60; Young