Crawford v. Marriott Hotel Services Inc.
Crawford v. Marriott Hotel Services Inc. (U.S. Court of Appeals, 11th Circuit, Nov. 1, 2021): The 11th Circuit ruled that under Georgia law Marriott did not owe a duty to warn a hotel patron with a seafood allergy that her chicken entrée contained crabmeat. The plaintiff claimed that Marriott was negligent and breached its duty to warn patrons of the latent dangers of seafood consumption. The court held that Marriot did not breach its duty of care because the hotel asked the banquet organizer if any attendees had allergies or special dietary requirements and communicated with the organizer that patrons with seafood allergies could be served a chicken entrée without seafood. The organizer did not respond with information about any attendees’ allergies. Plaintiff failed to inform the hotel or banquet organizer of her seafood allergy. Marriott met its duty in its communications with the organizer, as evidenced by a signed banquet order reflecting 30 crab-stuff chicken breasts and an unmarked dietary restriction box. Read the decision here.