This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Plaintiff, a visitor at Sandia Resort and Casino, played a slot machine that displayed winnings of $1,597,244.10. The Defendant, Sandia Resort and Casino, refused to pay, claiming the machine malfunctioned, voiding all play. The Plaintiff exhausted tribal remedies through the Sandia Gaming Commission, which upheld the non-payment decision (paras 2-3).
Procedural History
- District Court of Bernalillo County: The court dismissed the Plaintiff's claims for breach of contract, prima facie tort, and violation of the Unfair Practices Act, holding that tribal sovereign immunity barred the suit (paras 3, 10).
Parties' Submissions
- Plaintiff-Appellant: Argued that the Tribal-State Class III Gaming Compact waived sovereign immunity for his claims and that factual disputes regarding the casino's relationship to the Pueblo and the machine malfunction precluded dismissal. Additionally, he contended that sovereign immunity is outdated and should not apply (paras 3-4, 7, 19-20).
- Defendant-Appellee: Asserted that the casino, as a wholly-owned enterprise of the Pueblo of Sandia, is protected by tribal sovereign immunity, which was not waived under the Compact. The Defendant also argued that the Plaintiff failed to allege physical injury to person or property as required under the Compact (paras 3, 10-13).
Legal Issues
- Whether tribal sovereign immunity barred the Plaintiff's claims for breach of contract, prima facie tort, and violation of the Unfair Practices Act.
- Whether the Tribal-State Class III Gaming Compact waived sovereign immunity for the Plaintiff's claims.
- Whether factual disputes precluded dismissal of the case.
Disposition
- The Court of Appeals affirmed the district court's dismissal of the Plaintiff's claims, holding that tribal sovereign immunity barred the suit and that the Compact did not waive immunity for the Plaintiff's claims (para 23).
Reasons
Per Castillo J. (Kennedy and Vigil JJ. concurring):
Sovereign Immunity as a Legal Principle: The Court rejected the Plaintiff's argument to abandon sovereign immunity, citing binding precedent from the United States Supreme Court and New Mexico Supreme Court, which recognize tribal sovereign immunity as a legitimate doctrine (paras 5-6).
Factual Disputes: The Court found no merit in the Plaintiff's claim that factual disputes precluded dismissal. The Plaintiff failed to allege facts in his complaint that would establish the casino as separate from the Pueblo or justify discovery. Additionally, the Plaintiff did not pursue discovery during the case's pendency (paras 7-10).
Waiver of Sovereign Immunity: The Court held that the Compact's waiver of sovereign immunity is limited to claims for physical injury to persons or property caused by the gaming enterprise. The Plaintiff's claims for unpaid winnings did not constitute physical injury or property damage under the Compact. The Court relied on prior case law, which interpreted the Compact to exclude contract and tort claims unrelated to physical injury (paras 11-21).
Regulation of Gaming: The Court dismissed the Plaintiff's argument that Sandia's actions violated the Compact's purpose of ensuring fair and honest gaming. The Court reiterated that sovereign immunity applies unless explicitly waived, and the Plaintiff's claims did not fall within the scope of the Compact's waiver (para 22).