Mr_Pacman, the claim check the hotel gave your wife probably has some legal language on it describing the hotel's liability.

In general, state laws limit hotel liability (Innkeepers Laws), even when the items are in the control of the hotel, unless they are locked in the hotel's safe. Whether that's good or bad, it's the law.

I tried to google New York state innkeepers laws, but didn't get very far. That's where your info will be.