Flores v. Las Vegas-Clark Cnty. Library Dist.

Summary

The Nevada Supreme Court held that Senate Bill 175's firearm-preemption provisions expressly apply to counties, cities, and towns, but not to library districts. Accordingly, the Las Vegas-Clark County Library District could enforce its policy prohibiting firearms on library premises, and the court affirmed summary judgment for the District. Two justices dissented, concluding that the statute's purpose and legislative history demonstrated broader preemption.

Holdings

1. Senate Bill 175 unambiguously preempts firearm regulation by counties, cities, and towns, but it does not expressly preempt a library district from regulating firearm possession on its premises.
2. The court did not need to decide whether the county or city could convey authority they themselves lacked because the library district's authority to regulate library management came directly from the Legislature, and Senate Bill 175 did not expressly revoke that authority.

Questions Presented

1. Whether Senate Bill 175 expressly preempts a library district from regulating firearm possession on its premises.
2. Whether the district's Dangerous Items Policy is preempted because the library district was jointly created by Clark County and the City of Las Vegas.

Disposition

affirmed