Humphries v. New York-New York Hotel & CasinoAnnotate this Case
The Supreme Court reversed the district court’s order granting summary judgment in favor of Respondent-casino, holding that the district court’s foreseeability analysis under Nev. Rev. Stat. 651.015 was too restrictive.
Appellants sued Respondent for injuries they suffered during an altercation with another patron on Respondent’s casino floor. The district court concluded that Respondent did not owe a duty to Appellants under section 651.015 because Respondent had no “notice or knowledge” the other patron would assault Appellants. The Supreme Court reversed and remanded this matter for further proceedings, holding that the district court failed properly to consider section 651.015(3)(b) - which requires a case-by-case analysis of similar wrongful acts, including the level of violence, location of the attack, and security concerns implicated - and that the record showed Respondent’s knowledge of similar on-premises wrongful acts.