## Facts

- Soheil Sadri, a California resident, gambled at a licensed Nevada casino over two days and incurred $22,000 in gambling losses.
- To obtain chips for gambling, Sadri delivered two personal checks ($2,000 and $10,000) and two casino credit instruments (“markers”) for $5,000 each.
- After losing the chips in casino gambling, Sadri stopped payment on the checks and markers drawn on his California bank.
- Nevada law (Nev. Rev. Stat. § 463.368) provides that casino credit instruments and the represented gambling debts are valid and enforceable by legal process.
- The casino assigned its claim to Metropolitan Creditors Service of Sacramento (MCS), which sued Sadri in California to collect the $22,000 rather than seeking a Nevada judgment.

## Issues

1. Whether a California court must enforce a Nevada cause of action on casino credit instruments when Nevada law makes the instruments and resulting gambling debts enforceable.
2. Whether California may refuse enforcement of the Nevada-based claim because judicial enforcement of gambling-on-credit debts contravenes California public policy.
3. Whether the absence of a sister-state judgment affects any obligation to enforce the claim under full faith and credit or comity.

## Decision

- The Court of Appeal affirmed judgment for Sadri.
- California courts may refuse to enforce a Nevada cause of action seeking collection of casino credit extended for gambling because it conflicts with California’s strong public policy against judicial enforcement of gambling-on-credit debts.
- Full faith and credit did not compel enforcement because MCS sought enforcement of a foreign cause of action, not recognition of a Nevada judgment.
- The assignment to MCS did not change the nature of the claim; the assignee stood in the casino’s position for enforcement purposes.

## Legal Principles

- A forum state may decline to apply or enforce another state’s law where enforcement would violate a strong and established forum public policy, particularly when only a cause of action (not a sister-state judgment) is presented.
- Full faith and credit generally requires recognition of sister-state judgments, but does not require a forum to entertain a foreign cause of action that substantially conflicts with the forum’s fundamental policy.
- Comity is discretionary and may be withheld when enforcement would require the forum’s courts to provide judicial remedies inconsistent with the forum’s policy.
- California’s policy tolerating or regulating some gambling does not imply willingness to use its courts to collect gambling debts incurred on credit.

## Conclusion

The court held that, absent a Nevada judgment, California could refuse to enforce a Nevada statutory claim on casino checks and markers because compelling collection of gambling-on-credit obligations would conflict with California’s longstanding public policy against judicial enforcement of such debts.


Metropolitan Creditors Serv. of Sacramento v. Sadri, 15 Cal. App. 4th 1821, 19 Cal. Rptr. 2d 646 (Ct. App. 1993)