Justia Nevada Supreme Court Opinion Summaries

Sky Moore rented a car from Budget Car and Truck Rental of Las Vegas, owned by Malco Enterprises of Nevada, Inc. Sky named Daniel Moore as an additional driver, who later rear-ended Alelign Woldeyohannes while intoxicated. Alelign sued Daniel for negligence and Malco for negligent entrustment. Daniel did not respond, resulting in a default judgment against him. The case proceeded to arbitration, where Alelign was awarded $32,680.26. Malco requested a trial de novo, leading to a short trial where the judge entered a default judgment against Daniel for $37,886.82.Alelign moved to apply the default judgment against Malco under NRS 482.305(1), which holds short-term lessors liable for damages if they fail to provide minimum insurance coverage. Malco opposed, arguing that NRS 482.305 is preempted by the Graves Amendment, which prohibits states from holding vehicle lessors vicariously liable without negligence or wrongdoing. The short trial judge granted Alelign’s motion, and the district court affirmed, concluding that NRS 482.305 is a financial responsibility law preserved by the Graves Amendment’s savings clause.The Supreme Court of Nevada reviewed the case and affirmed the district court’s judgment. The court held that NRS 482.305 is not preempted by the Graves Amendment because it is a financial responsibility law preserved by the savings clause under 49 U.S.C. § 30106(b). The court emphasized that NRS 482.305 imposes a legal requirement for lessors to provide minimum coverage, rather than a mere financial inducement, and does not impose strict vicarious liability on lessors. View "Malco Enterprises of Nevada, Inc. vs. Woldeyohannes" on Justia Law

The Supreme Court reversed the order of the district court as to Appellants' motions to compel arbitration and remanded the case, holding that "where the nonsignatory seeking to compel arbitration demonstrates both the right to enforce the contract and that compelling another nonsignatory to arbitration is warranted under standard principles of contract law or estoppel, compelling arbitration is appropriate."At issue was whether a nonsignatory to a contract containing an arbitration clause can be compelled to participate in arbitration by another signatory. The district court denied both Appellants' first and second motions to compel arbitration. The Supreme Court reversed as to Appellants' first and second motions to compel arbitration, holding where a nonsignatory to a contract containing an arbitration provision moves to compel another nonsignatory to arbitrate, the nonsignatory seeking to compel arbitration must demonstrate the right to enforce the arbitration agreement and show that compelling the other nonsignatory to arbitration is warranted. View "RUAG Ammotec GmbH v. Archon Firearms, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court compelling an estate's claims to arbitration pursuant to an arbitration agreement signed during the decedent's admission to El Jen Convalescent Hospital and Retirement Center (El Jen), holding that a nonsignatory heir's wrongful death claim is not bound to an agreement like the arbitration agreement in his case that does not implicate the viability of the underlying personal injury claim.Following the death of her husband, Gary Tyler, Stacy Tyler brought this action against El Jen, asserting negligence, wrongful death, and survivorship claims individually and on behalf of Gary's estate and their minor child, and was joined by two adult statutory heirs. The district court (1) compelled the estate's claims to arbitration pursuant to the arbitration signed during Gary's admission to El Jen; and (2) concluded that the statutory heirs were not bound by the agreement because they did not sign it. The Supreme Court affirmed, holding that the district court (1) properly rejected Plaintiffs' challenge to the arbitration agreement's validity; and (2) did not err in holding that the heirs were not bound by the agreement because they were nonsignatories who were pursuing their own individual claims. View "El Jen Medical Hospital, Inc. v. Tyler" on Justia Law

The Supreme Court reversed the order of the district court setting aside a judgment confirming an arbitration award under Nev. R. Civ. P. 60(b) (NRCP 60(b)), holding that Nevada Arbitration Rule (NAR) 19(C) bars a district court from setting aside a judgment confirming gan arbitration award under NRCP 60(b).On appeal from a district court judgment confirming an arbitration award under NRCP 60(b), Appellant argued that NAR 19(C) barred the district court from applying NRCP 60(b) to set aside the judgment. The Supreme Court agreed and remanded the case with instructions to reinstate the judgment, holding that NAR 19(C) barred post-judgment relief under NRCP 60(b). View "Arce v. Sanchez" on Justia Law

The Supreme Court held that the district court erred in denying Appellant's motion to compel arbitration and refusing to submit the arbitrability determination under the circumstances of this case to an arbitrator.Plaintiffs sued Airbnb, Inc. for wrongful death and personal injury alleging that Airbnb's services had been used by a party's host to rent the house where a shooting occurred, resulting in a fatality. Airbnb moved to compel arbitration, arguing that Plaintiffs had agreed to Airbnb's Terms of Service during the registration process for their accounts. The district court denied the motion to compel. The Supreme Court reversed, holding that because the Federal Arbitrability Administration governed the enforcement of arbitration agreement at issue, and because the agreement delegated the arbitrability question to an arbitrator, the district court erred in deciding the arbitrability question. View "Airbnb, Inc. v. Rice" on Justia Law

The Supreme Court reversed the order of the district court denying Appellant's motion to compel arbitration, holding that where an arbitration agreement delegates the threshold question of arbitrability to the arbitrator, the district court must refer to the case to arbitration, even if the court concludes that the dispute is not subject to the arbitration agreement.Respondents filed a personal injury lawsuit against Uber after their Uber driver rear-ended another Uber driver. Uber moved to compel arbitration on the grounds that Respondents had agreed to arbitrate their claims. The district court denied the motion, concluding that the arbitration agreement did not plainly provide that the parties agreed to submit this particular dispute to arbitration. The Supreme Court reversed, holding that where the arbitration agreement's delegation clause expressly requires the arbitrator to determine threshold issues of arbitrability, the district court erred by denying Uber's motion to compel on the ground that the claims were not subject to the arbitration agreement. View "Uber Technologies, Inc. v. Royz" on Justia Law

The Supreme Court reversed the order of the district court denying SR Construction, Inc.'s motion to compel arbitration because its master subcontract agreement (MSA) with Peek Brothers Construction, Inc. constituted a valid arbitration provision that applied to the parties' underlying dispute, holding that the dispute was arbitrable.On appeal, SR argued that the district court erred in holding that the underlying dispute fell outside the bounds of the parties' arbitration agreement.The Supreme Court agreed and reversed, holding (1) as applied, the MSA provision was broad, and an attendant presumption of arbitrability applied; and (2) Peek's dispute was presumptively arbitrable under the parties' agreement. View "SR Construction, Inc. v. Peek Brothers Construction, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court concluding that an arbitration provision was void under Nev. Rev. Stat. 597.995 for failure to include a specific authorization, holding that the Federal Arbitration Act (FAA), 9 U.S.C. 1 et seq., preempted section 597.955, and therefore, the district court's decision was erroneous.Nev. Rev. Stat. 597.995 requires any agreement that includes an arbitration provision to include a specific authorization for that provision. The district court concluded that the arbitration provision at issue in this case was void for failure to include a specific authorization, as required by section 597.995. The Supreme Court reversed, holding (1) because section 597.995 singles out and disfavors arbitration provisions by imposing stricter requirements on them than on other contract provisions, the FAA preempts the statute in cases involving interstate commerce; and (2) the district court erred by concluding that section 597.995 voided the parties' arbitration agreement. View "Maide, LLC v. Dileo" on Justia Law

The Supreme Court affirmed the judgment of the district court confirming an arbitration award in a commercial contract matter, holding that there was no error.The parties in this case were two newspapers with a lengthy contractual relationship. The parties' contract contained a provision submitting disputes arising out of the contract to binding private arbitration. A dispute arose over amounts owed under the parties' contract, and the matter was submitted to arbitration. After the arbitrator rendered an award, both parties sought to vacate portions of the award by arguing that the arbitrator's award was so egregiously wrong that the arbitrator had clearly failed to apply the contract at all. The district court confirmed the award. The Supreme Court affirmed, holding that the district court properly found that there was no clear and convincing evidence that the arbitrator had exceeded his powers, acted arbitrarily and capriciously, or manifestly disregarded the law. View "News+Media Capital Group LLC v. Las Vegas Sun, Inc." on Justia Law

The Supreme Court granted writ relief in this case concerning whether the district court has authority to intervene in binding arbitration to sanction a party's misconduct, holding that the district court improperly intervened in this matter.The parties agreed to Plaintiff filing a complaint, staying the action, selecting an arbitrator, and allowing the case to proceed through arbitration. After an improper sweep of Plaintiff's technology, Defendant filed a motion for discovery sanctions. The arbitrator fined Plaintiff but declined to strike Plaintiff's claims at that time, as requested by Defendant. Defendant then filed a motion in the district court for provisional relief, requesting that the court take action to remedy the misconduct. The district court found that it had the authority to address the issues raised in the motion. The Supreme Court granted Plaintiff's petition for writ relief, holding (1) where Nev. Rev. Stat. 38.222 provides limited authority to intervene in an arbitration only where the district court orders a provisional remedy and where the court did not order a provisional remedy in this case, the district court lacked authority under section 38.222 to intervene in the arbitration; and (2) the district court did not have inherent authority to intervene in the arbitration because the alleged litigation misconduct was squarely before the arbitrator. View "Direct Grading & Paving v. Eighth Judicial District Court" on Justia Law