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Arguello v. Sunset Station, Inc., 252 P.3d 206 (Nev. 2011)

As noted below, many states have laws that limit the liability of innkeepers for their guests’ personal property. However, there are some exceptions to these protections. In Arguello v. Sunset Station, Inc., the plaintiff sued Sunset Station Hotel & Casino when his car was stolen after it was parked in the casino’s lot by a valet. Nevada’s NRS 651.010(1) limits the liability of hotels for “the theft, loss, damage or destruction of any property brought by a patron upon the premises or left in a motor vehicle upon the premises . . . in the absence of gross neglect by the owner or keeper” of the hotel. The court recognized that the broad language of the statue could apply to literally any property, including motor vehicles. However, the court took a narrower reading and argued that the phrase “or left in a motor vehicle upon the premises” places motor vehicles outside of the statute’s scope. A motor vehicle cannot be left inside a motor vehicle, and so the court reasoned that the Nevada legislature had not intended the law to apply to the theft of motor vehicles. Therefore, the court ruled in favor of Arguello.

 
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