## Facts

- Kenneth W. Corbin placed a $100 wager at 200-to-1 odds at the Jockey Turf Club that the Boston Red Sox would win the American League pennant for the 1967 season.
- After the Red Sox won the pennant, Corbin demanded payment of $20,000 as winnings.
- The proprietors and related respondents refused to pay, asserting the wager was taken by an employee who failed to record it and allegedly kept the money, so the club did not receive the bet.
- Corbin and his attorneys submitted the dispute to the Nevada Gaming Control Board, which denied his claim.
- Corbin then filed a civil action in Nevada district court seeking to enforce the wager and recover $20,000 as a gambling debt.
- The respondents moved to dismiss on the ground that gambling debts are not judicially collectible in Nevada.
- The district court granted the motion to dismiss, and Corbin appealed.

## Issues

1. Whether Nevada courts may entertain a civil action to enforce and collect a gambling debt arising from a winning wager placed at a licensed gambling establishment.
2. Whether allegations referencing the Nevada Gaming Control Board’s handling of the dispute transform the lawsuit into judicial review of administrative action, rather than a suit to collect a gambling debt.

## Decision

- The Supreme Court of Nevada affirmed the district court’s dismissal.
- The court held the complaint presented a suit to recover a gambling debt, and Nevada courts will not aid in the collection of such debts.
- The court declined to treat the case as an administrative review proceeding and therefore did not decide questions about reviewability of the Board’s procedures, arbitrariness, or exhaustion of administrative remedies.
- The court refused to overturn its earlier precedent rejecting judicial enforcement of gambling obligations.

## Legal Principles

- A civil action whose substance is the recovery of a gambling debt is not maintainable in Nevada courts, even if the wager occurred in a legal, licensed gambling establishment.
- References in a complaint to perceived arbitrariness or unfairness by the Nevada Gaming Control Board do not convert a debt-collection lawsuit into a properly presented petition for judicial review of administrative action.
- Stare decisis applied: prior Nevada decisions establish a longstanding rule that courts will not assist in collecting gambling debts, and the court will not depart from that rule absent an express change in law or a deliberate overruling, which the court declined to do here.
- When a case is controlled by settled precedent on nonenforceability of gambling debts, policy arguments based on the legality or regulation of gambling do not, by themselves, justify judicial enforcement of the obligation.

## Conclusion

The Nevada Supreme Court treated Corbin’s claim as an attempt to collect gambling winnings through a civil action and reaffirmed Nevada’s longstanding rule that courts will not enforce gambling debts, affirming dismissal without reaching administrative-law questions about the Gaming Control Board’s denial of relief.


Corbin v. O'Keefe, 484 P.2d 565 (Nev. 1971)