Friedlander v. Tamarack Junction Race & Sports Book

Summary

The Nevada Supreme Court affirmed a district court order upholding a Nevada Gaming Control Board decision concerning the payout of two Kentucky Derby wagers. The court held that William Hill's posted house rules limiting exacta and trifecta odds provided sufficient notice and controlled the wagers' payout terms. The Board's decision was supported by evidence and was not arbitrary, capricious, or contrary to law.

Holdings

1. The Board's finding that William Hill conspicuously displayed the limited-odds terms was supported by evidence, including the posted notices, the house-rules printout, and the betting sheets.
2. When an establishment's house rules are conspicuously displayed so that patrons have notice of them, those rules govern the payout terms of gaming wagers, regardless of whether the patron actually read or knew the terms.
3. The Board's decision to enforce the posted limited-odds terms was not arbitrary, capricious, or contrary to law.
4. A patron may not challenge a gaming payout through a breach-of-contract claim; the dispute must be submitted to the Nevada Gaming Control Board under the exclusive statutory administrative process.

Questions Presented

1. Whether the Nevada Gaming Control Board's determination that William Hill adequately disclosed and could apply its limited exacta and trifecta odds was supported by evidence.
2. Whether the Board's decision was arbitrary, capricious, or contrary to law because it applied posted house rules and contract principles rather than awarding full track odds.
3. Whether Friedlander could challenge the gaming payout through a breach-of-contract theory rather than through the exclusive administrative process governing gaming disputes.

Disposition

affirmed