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Keywords

contractplaintiffjurisdictionstatutemotiondue processwrit of prohibition
contractplaintiffdefendantjurisdictionstatutedue processwrit of prohibition

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Trump v. Eighth Judicial Dist. Court of State of Nev. In and For County of Clark, 109 Nev. 687, 857 P.2d 740

Facts

Dennis Gomes, while employed as CEO of the Golden Nugget Hotel and Casino in Las Vegas, entered into a conflicting employment contract with Trump Taj Mahal Associates to become the president and COO of the Trump Taj Mahal Casino Resort. GNLV Corp. subsequently sued Trump for intentional interference with Gomes' contract with them, serving him in New York. Trump moved to quash the service, claiming lack of personal jurisdiction, but the district court denied his motion, leading to Trump's petition for a writ of prohibition.

While Dennis Gomes (Gomes) was acting, pursuant to an employment contract, as president and chief executive officer (CEO) of the Golden Nugget Hotel and Casino (Golden Nugget) in Las Vegas, owned by real party in interest GNLV Corp. (GNLV), Trump Taj Mahal Associates entered into a conflicting employment contract with Gomes to employ him as the president and chief operating officer (COO) of the Trump Taj Mahal Casino Resort (the Taj Mahal).

Issue

Did the district court have personal jurisdiction over Donald J. Trump in the case brought by GNLV Corp. for intentional interference with contractual relations?

Did the district court have personal jurisdiction over Donald J. Trump in the case brought by GNLV Corp. for intentional interference with contractual relations?

Rule

To establish personal jurisdiction, a plaintiff must show that the state's long-arm statute is satisfied and that exercising jurisdiction does not offend due process, which requires minimum contacts with the forum state.

To obtain jurisdiction over a non-resident defendant, a plaintiff must show: (1) that the requirements of the state's long-arm statute have been satisfied, and (2) that due process is not offended by the exercise of jurisdiction.

Analysis

The court found that GNLV made a prima facie showing of personal jurisdiction based on the actions of Trump's agent, Ribis, who negotiated Gomes' employment contract. The court determined that Ribis acted as Trump's personal agent, and thus his contacts with Nevada were attributable to Trump. The court concluded that Trump purposefully directed his conduct toward Nevada through these contacts, satisfying the requirements for specific personal jurisdiction.

We conclude that GNLV made a prima facie showing that Ribis acted at least in part as Trump's personal agent when Ribis negotiated Gomes' employment contract.

Conclusion

The Supreme Court of Nevada denied Trump's petition for a writ of prohibition, affirming that the district court did not err in exercising personal jurisdiction over him.

We conclude that the district court did not err in exercising personal jurisdiction over Trump, and we therefore deny this petition for a writ of prohibition.

Who won?

GNLV Corp. prevailed in the case as the court upheld the district court's exercise of personal jurisdiction over Trump, finding sufficient contacts through his agent.

GNLV presented no evidence that Trump: (1) owns any property in Nevada or has any interest in any property in Nevada; (2) has physically entered the state of Nevada; (3) has conducted business in Nevada or engaged in any persistent course of conduct within the state; or (4) derives any revenues from any goods consumed or services rendered within Nevada.

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