Terra Shepard

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Case Synopsis

The Nevada Supreme Court upheld a lower court’s dismissal of an employment discrimination case. Boyd Gaming Corporation (“Boyd”) terminated Salloum’s employment. The limitation period for an employment discrimination claim expired 180 days after the alleged discriminatory action. In 2019, the legislature amended NRS 613.430 to extend the limitation period, and Salloum subsequently filed a claim. Boyd filed a motion to dismiss, arguing that Salloum’s claims expired under the previous version of the statute and the amended statute did not apply. The lower court agreed with Boyd and dismissed the claim. The lower court also found that equitable tolling did not apply.

Because the amendment to NRS 613.430 did not explicitly state that it applied retroactively, the Court held that the district court was correct. The Court found that equitable tolling did not apply because Salloum did not establish that his failure to timely file his claim resulted from factors he could not control.