Harrah's Atlantic City Had No Duty to Withhold Credit From Compulsive Gambler, Court Says
Harrah's “is in the business of operating casino gambling; defendant is its customer," the panel said, affirming a judgment of nearly $188,000. "The relationship is built on enabling gaming, not withholding it.”
April 26, 2019 at 05:57 PM
6 minute read
An appellate panel ruled Friday that Harrah's Atlantic City casino can go ahead with its effort to collect a debt from a self-described compulsive gambler who ran up his credit line with the casino and couldn't pay it back.
The panel affirmed an earlier decision in Atlantic County Superior Court against the defendant, Massimo Dangelico, that the casino company was not under a duty to not extend credit to him because of his compulsion.
“We are satisfied that Harrah's demonstrated the absence of a genuine issue of material fact, and it was entitled to judgment as a matter of law,” the panel said in its ruling upholding a nearly $188,000 judgment.
“Defendant bears the burden to prove his affirmative defense. He has failed to demonstrate a violation of the statutory and regulatory framework … governing extension of credit by casinos, which may constitute a defense,” the panel said.
The panel said Dangelico also failed to identify the “central credit registry” that he said listed him as someone not to be loaned money, or prove that he is on that registry.
The decision examined whether casinos should restrict the activities of compulsive gamblers.
Harrah's had lent Dangelico $160,000 against a $200,000 line of credit, according to the decision.
The loan was secured by counterchecks drawn on Dangelico's bank. Dangelico maintained he had funds on deposit with his bank equal to the funds the casino provided. When Dangelico failed to repay the loan, Harrah's deposited the checks, but the bank dishonored them for insufficient funds, said the court.
In his appeal, Dangelico did not dispute the facts of the loan, his default, and the dishonoring of his checks.
His sole defense was that Harrah's should not have extended him credit in the first place because he is a compulsive gambler, had defaulted on “casino markers” with other casinos, and his “name was placed in a central credit registry not to extend to him credit because of his addiction.”
When Dangelico failed to repay the $160,000 loan, Harrah's began the debt collection process, seeking judgment in the amount of the loan, plus interest and attorney fees.
After a period of discovery, Atlantic County Superior Court Judge Mary Siracusa entered summary judgment in favor of Harrah's in December 2017, according to electronic court documents. The court granted Harrah's summary judgment in the amount of $188,697.31, including interest and $1,500 in attorney fees.
The appeal was heard by Appellate Division Judges Ellen J. Koblitz and Mitchell Ostrer.
The panel said it is difficult for casinos to distinguish compulsive gamblers from recreational gamblers, or to set reasonable limits on compulsive gamblers—particularly ones who, like Dangelico, represented that they had funds on deposit to support their activities.
“We are not convinced the public interest supports recognizing a duty to withhold credit from a patron who has not availed himself of the mechanisms the law provides to protect himself from his compulsiveness to gamble,” the panel wrote in the per curiam decision.
The panel said Dangelico could have taken steps to prevent getting a casino credit line, including asking the Division of Gaming Enforcement to place him on a list of individuals ineligible for casino credit, or place himself on a list of persons self-excluded from gaming activities. He did none of these things, according to the court.
The panel said Dangelico also failed to show proof of any unpaid checks when Harrah's extended him new credit.
“A casino is not liable to any self-excluded person for harm that may result from allowing the excluded person to gamble. … Even if he is a compulsive gambler, defendant cites no authority for the proposition that proof of that condition alone demonstrates incapacity to enter into an agreement to borrow funds for gambling,” the panel said. “Compulsiveness does not belie understanding the nature and effect of one's actions.”
The panel said Dangelico did not present a duress defense because he has not demonstrated that the casino exerted wrongful pressure to overcome his free will, nor did he establish that his claimed compulsiveness obliged Harrah's to deny him credit.
“First, defendant provides no evidence that the casino was aware he was a compulsive gambler. Being a bad credit risk is not the same as being a compulsive gambler,” the panel wrote.
Added the panel: “Our Supreme Court has outlined the factors governing whether to recognize a duty of care from one toward another: Whether a person owes a duty of reasonable care toward another turns on whether the imposition of such a duty satisfies an abiding sense of basic fairness under all of the circumstances in light of considerations of public policy.
“Applying those factors, we are not prepared to recognize a duty that Harrah's owed defendant to deny him credit,” wrote the panel, adding, “We do not depreciate the financial ruin that may befall compulsive gamblers and their dependents.”
But Harrah's, the panel said, “is in the business of operating casino gambling; defendant is its customer. The relationship is built on enabling gaming, not withholding it.”
Of nine land-based casinos in Atlantic City, Harrah's ranked third in gross revenue last month from table games and slot machines at $26.4 million. It came behind market leading Borgata at $59.4 million and Tropicana at $27.3 million and just ahead of fourth-place Hard Rock Casino Hotel at $24.6 million, according to March 2019 figures from the New Jersey Division of Gaming Enforcement which tracks the industry.
Mark S. Carter, a lawyer in Hackensack who represented Dangelico, had no comment on the decision when reached by phone on Friday.
Craner, Satkin, Scheer, Schwartz & Hanna in Scotch Plains represented Harrah's Entertainment. The firm had no comment.
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