Despite multiple warning from a man's family that he was at risk of harming himself while staying at a Motel 6, the Massachusetts Court of Appeals held that employees had no duty to take reasonable steps to prevent his suicide.

The state has previously held that innkeepers do have a special duty to their guests and have some duty to take reasonable steps to prevent certain types of harm, such as maintaining an adequate security system to prevent a guest from being stabbed by an intruder, as held in Fund v. Hotel Lenox of Boston (1994), and taking reasonable steps to protect a guest from assault by another guest, as decided in McFadden v. Bancroft Hotel (1943), as well as Restatement (Third) of Torts: Liability for Physical and Emotional Harm §40(b)(2).