Document Type

Case Summary

Publication Date

1-1-2003

Case Synopsis

Respondents, Dedric Holman and Christina Edwards, were gambling at the Gold Coast Hotel when a physical confrontation arose between John Nittinger, a security guard, and Holman. When Holman tried to run, security officers pursued him and held him to the ground. According to Holman’s testimony, the guards made racial slurs, punched, kicked and beat him. The security shift supervisor was present during part of the incident. The district court instructed the jury that it could find the Gold Coast liable for punitive damages if a “managerial agent” authorized or ratified the guards’ conduct. The jury awarded respondents $198,000 in compensatory damages from the security guards and the Gold Coast. The jury also awarded the respondents $371,000 in punitive damages from the Gold Coast. On appeal, appellant Gold Coast argued that because the security shift supervisor was not a managerial agent, it could not be liable for punitive damages. The Nevada Supreme Court agreed, therefore reversing the imposition of punitive damages on the Gold Coast.

Share

COinS