Nev. Rev. Stat. » NRS: CHAPTER 463 - LICENSING AND CONTROL OF GAMING
Nevada Revised Statutes

Nev. Rev. Stat. § 463.361 (2026)

Enforceability and resolution of gaming debts

✓ current as of July 2026
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NRS 463.361  Enforceability and resolution of gaming debts.

      1.  Except as otherwise provided in NRS 463.361 to 463.366, inclusive, and 463.780, gaming debts that are not evidenced by a credit instrument are void and unenforceable and do not give rise to any administrative or civil cause of action.

      2.  A claim by a patron of a licensee for payment of a gaming debt that is not evidenced by a credit instrument may be resolved in accordance with NRS 463.362 to 463.366, inclusive:

      (a) By the Board; or

      (b) If the claim is for less than $1,000, by a hearing examiner designated by the Chair of the Board.

      (Added to NRS by 1983, 1846; A 1991, 929; 2001, 3086; 2025, 425)

     

Notes of Decisions
Cited in 9 cases (3 in the last 5 years), 1985–2026 · leading case: Sengel v. IGT, 2 P.3d 258 (Nev. 2000).
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Sengel v. IGT, 2 P.3d 258 (Nev. 2000). · cites it 4× “1 NRS 463.361 provides, as follows: 1. Except as otherwise provided in NRS 463.”
Sigel v. McEvoy, 707 P.2d 1145 (Nev. 1985). · cites it 4× “” Thus, the legislature to some extent modified the common law prohibition against enforcement of gaming debts. NRS 463.361(1), however, was enacted after the parties entered into their agreement and after the *625 two tournaments in question.”
Konstantin Zoggolis v. Wynn Las Vegas, LLC (9th Cir. 2014). · cites it 12× “The panel also held that because the markers were credit instruments, Zoggolis’ claims did not trigger the Gaming Control Board’s exclusive jurisdiction over a “gaming debt that is not evidenced by a credit instrument” under Nev. Rev. Stat. § 463.361 (2). The panel concluded…”
Manley v. MGM Resorts Int'l (D. Nev. 2023). · cites it 4× “Gibilterra is inapposite here because this case involves gambling-related credit 2 Gaming Control Board because it has “exclusive jurisdiction” under NRS § 463.361. (ECF 3 No. 27 at 6.) On one hand, the Nevada Supreme Court does not appear to have squarely 4 addressed the issue…”
Desert Palace, Inc. v. Michael, 370 F. Supp. 3d 1177 (D. Nev. 2019). “In support, he relied exclusively on NRS 463.361, which states that "gaming debts that are not evidenced by a credit instrument are void and unenforceable and do not give rise to any administrative or civil cause of action.”
Est. of Chagra v. Comm'r, 60 T.C.M. 104 (Tax Ct. 1990). · cites it 2× “In addition, to the extent that they may be appropriate, the rules of evidence contained in the Federal Rules of Civil Procedure will apply. Rule 143(a).”
Desert Palace, Inc. v. Michael (D. Nev. 2020). · cites it 2× “17 Michael accuses me of “re- 9 writ[ing]” Nevada Revised Statutes (NRS)§ 463.361 to apply only to patrons,18 but I came to 10 that conclusionwith the aid of Nevada case law, Nevada Gaming Control Board (NGCB) 11 regulations, and the name of the statutory chapter where § 463.”
Toll v. Nevada Prop. 1 LLC (D. Nev. 2021). · cites it 2× “Additionally, if The Cosmopolitan believed 5 that recovery was subject to the administrative process of NRS § 463.361, it would have had a 6 duty to report the dispute to the NGCB.”
Friedlander v. Tamarack Junction Race & Sports Book (civil), 142 Nev. Adv. Op. No. 23 (Nev. 2026). · cites it 2× “NRS 463.361(1); NRS 463.362(1). Upon receiving such a complaint, the Board assigns an agent to investigate the claim and determine whether the gaming debt SUPREME COURT OF NEVADA 4 (01 IR47A should be paid.”
— Nev. Rev. Stat. § 463.361(1) — 3 cases
Sigel v. McEvoy, 707 P.2d 1145 (Nev. 1985). “” Thus, the legislature to some extent modified the common law prohibition against enforcement of gaming debts. NRS 463.361(1), however, was enacted after the parties entered into their agreement and after the *625 two tournaments in question.”
Sengel v. IGT, 2 P.3d 258 (Nev. 2000). “1 NRS 463.361 provides, as follows: 1. Except as otherwise provided in NRS 463.”
Friedlander v. Tamarack Junction Race & Sports Book (civil), 142 Nev. Adv. Op. No. 23 (Nev. 2026). “NRS 463.361(1); NRS 463.362(1). Upon receiving such a complaint, the Board assigns an agent to investigate the claim and determine whether the gaming debt SUPREME COURT OF NEVADA 4 (01 IR47A should be paid.”
— Nev. Rev. Stat. § 463.361(2) — 1 case
Manley v. MGM Resorts Int'l (D. Nev. 2023). “Gibilterra is inapposite here because this case involves gambling-related credit 2 Gaming Control Board because it has “exclusive jurisdiction” under NRS § 463.361. (ECF 3 No. 27 at 6.) On one hand, the Nevada Supreme Court does not appear to have squarely 4 addressed the issue…”
— Nev. Rev. Stat. § 463.361(2)(a) — 1 case
Sengel v. IGT, 2 P.3d 258 (Nev. 2000). “1 NRS 463.361 provides, as follows: 1. Except as otherwise provided in NRS 463.”
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