Helton V. Glenn Enterprises Case Study

Helton v Glenn Enterprises is a case in Tennessee involving a hotel and a guest. The guest drove a large rig that hauled a drag racing car. The hotel did not have sufficient parking for Mr. Helton's rig. Close to the hotel was an area where Mr. Helton parked his rig. The area was lined for parking spaces and Mr. Helton observed a bus load of guests getting off of the bus and coming into the hotel. Mr. Helton asked the hotel front desk clerk if it will be all right to park his rig there. The clerk answered in the affirmative even though the hotel did not own the property. Signage was absent at the lot. (Helton v. Glenn Enterprises, 2006)

The clerk had been instructed to inform any guests that specifically asked about that parking space
was a similar case. In this case Mr. Samdler parked his car in a lot and the lot attendant asked for the keys. Mr. Samdler left his keys and was given a claim ticket. The car was stolen and in this case the court ruled that because the transfer of keys had taken place the vehicle was now in possession of the lot and proper bailment had occurred.(Liability,1963) Because of this the lot was held liable for the loss of the car.

In the search to find case law supporting the decision in Helton v Glenn Enterprises one case found the lot liable even when no transfer of keys had been made, another court, in another state found under similar circumstances the lot not to be liable. The last case examined the court ruled against the lot because a transfer of keys had been made. Each case was heard in a different state. One in New York, Massachusetts (Samdler v Commonwealth Station Co.) and the last one in Oklahoma.

Another definition of bailment and parking lots is that bailment takes place when a fee has been paid but free parking no bailment takes place. Bailment is apparently defined differently in different states regarding parking. The original case, Helton v Glenn Enterprises, took place in Tennessee. To determine what constitutes bailment in Tennessee the case Freddie Stewart v HCA Health Services Of Tennessee, Inc. was examined. This was a case heard on
No payment had been made, keys were retained by the owner, no claim check had been given and the usual disclaimer found on claim checks posted . (Stewart v HCA Health Services, 1997)

In the case Helton v Glenn Enterprises no payment had been made. No transfer of keys had been made and no claim check given. The rig was parked on a lot not owned by the hotel. From examples of cases examined it does not appear any bailment was made between the hotel and Mr. Helton by these standards of bailment in Tennessee. (Liability Bailment Relationship, 2009)

Do I agree with the ruling? Reluctantly, yes. Judging from similar cases bailment did not happen and as such the hotel should not be liable. However, I do not believe the hotel acted in an ethical manner. They are certainly not people I would want to do business with. In defense of the hotel management did attempt to have local police involved in securing the lot but failing there in my opinion they should have posted notice about the parking lot. This seems to be the case here that perhaps in New York Mr. Helton might have prevailed. I would think that Mr. Helton would need more careful planning in the future with his rigs. Many hotels do not have facilities to park large rigs and he might be better served going to a truck stop type of hotel where suitable parking and security may be