Nev. Rev. Stat. » NRS: CHAPTER 651 - PUBLIC ACCOMMODATIONS
Nevada Revised Statutes

Nev. Rev. Stat. § 651.015 (2026)

Civil liability of innkeepers for death or injury of person on premises caused by person who is not employee under control or supervision of innkeeper

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NRS 651.015  Civil liability of innkeepers for death or injury of person on premises caused by person who is not employee under control or supervision of innkeeper.

      1.  An owner or keeper of any hotel, inn, motel, motor court, boardinghouse or lodging house is not civilly liable for the death or injury of a patron or other person on the premises caused by another person who is not an employee under the control or supervision of the owner or keeper unless:

      (a) The wrongful act which caused the death or injury was foreseeable; and

      (b) There is a preponderance of evidence that the owner or keeper did not exercise due care for the safety of the patron or other person on the premises.

      2.  An owner or keeper of any hotel, inn, motel, motor court, boardinghouse or lodging house is civilly liable for the death or injury of a patron or other person on the premises caused by another person who is not an employee under the control or supervision of the owner or keeper if:

      (a) The wrongful act which caused the death or injury was foreseeable; and

      (b) The owner or keeper failed to take reasonable precautions against the foreseeable wrongful act.

Ê The court shall determine as a matter of law whether the wrongful act was foreseeable and whether the owner or keeper had a duty to take reasonable precautions against the foreseeable wrongful act of the person who caused the death or injury.

      3.  For the purposes of this section, a wrongful act is not foreseeable unless:

      (a) The owner or keeper failed to exercise due care for the safety of the patron or other person on the premises; or

      (b) Prior incidents of similar wrongful acts occurred on the premises and the owner or keeper had notice or knowledge of those incidents.

      (Added to NRS by 1995, 2670)

     

Notes of Decisions
Cited in 21 cases (4 in the last 5 years), 2009–2025 · leading case: Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011).
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Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). · cites it 33× “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Bower v. Harrah's Laughlin, Inc., 215 P.3d 709 (Nev. 2009). “Moreover, in Nevada, the negligence issue hinged on foreseeability pursuant to NRS 651.015(1)(a), because to prove Harrah’s owed a duty, breached the duty, and caused appellants’ harm, appellants had to prove the wrongful act was foreseeable to Harrah’s.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). · cites it 58× “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Glover-Armont v. Cargile, 426 P.3d 45 (Nev. 2018). “2d 796 , 802 (1993) (vacating the district court's costs award made to the prevailing party in light of reversal), superseded by statute on other grounds, NRS 651.015, as recognized in Estate of Smith v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). · cites it 29× “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Cipriani v. Resorts World Las Vegas, LLC, No. 2:23-cv-01626 (D. Nev. Oct. 23, 2024). · cites it 18× “10 Cipriani specifically alleges a violation of NRS § 651.015, which prescribes the 11 liability of “owners” or “keepers” of hotels to their patrons when the patron is injured or 12 killed.”
Gauthier Vs. Wynn Las Vegas, Llc, No. 73238 (Nev. Oct. 24, 2019). · cites it 8× “3d 88 , 691 (2011) (discussing the application of NRS 651.015). The district court correctly found that appellants did not present evidence of Wynn's knowledge of prior similar incidents pursuant to NRS 651.”
Susan Hoy v. Jones, No. 2:18-cv-01403 (D. Nev. May 30, 2020). · cites it 6× “26 NRS 651.015 governs civil liability of innkeepers for the death or injury of a person on the 27 premises that was caused by someone other than an employee.”
Racine v. PHW Las Vegas, LLC, 46 F. Supp. 3d 1028 (D. Nev. 2014). · cites it 10× “Both parties have moved for summary judgment regarding the element of duty under NRS 651.015 (# 71 & # 75). Racine additionally seeks summary judgment on all remaining elements of NRS 651.”
Brunston v. Gaughan South LLC, No. 2:21-cv-01947 (D. Nev. Dec. 6, 2022). · cites it 5× “”34 15 South Point fails to present any authority indicating that a negligent-training claim predicated on 16 a failure to train employees on the casino’s ADA obligations cannot stand as a matter of law.”
Rios, No. 2:23-cv-01108 (D. Nev. Sept. 29, 2025). · cites it 5× “§ 651.015(2) (West 2025). 23 “If an injury is unforeseeable, then the innkeeper owes no duty, and the district court has no 24 occasion to consider the remaining elements of the plaintiffs cause of action .”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014). · cites it 7× “We note that under NRS 651.015, the district court was only tasked with determining whether such a crime was foreseeable, thereby imposing a duty on The Orleans.”
Show all 21 citing cases →
Nev. Rev. Stat. § 651.015(1): 1 case
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Nev. Rev. Stat. § 651.015(1)(a): 1 case
Bower v. Harrah's Laughlin, Inc., 215 P.3d 709 (Nev. 2009). “Moreover, in Nevada, the negligence issue hinged on foreseeability pursuant to NRS 651.015(1)(a), because to prove Harrah’s owed a duty, breached the duty, and caused appellants’ harm, appellants had to prove the wrongful act was foreseeable to Harrah’s.”
Nev. Rev. Stat. § 651.015(2): 8 cases
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Susan Hoy v. Jones, No. 2:18-cv-01403 (D. Nev. May 30, 2020). “26 NRS 651.015 governs civil liability of innkeepers for the death or injury of a person on the 27 premises that was caused by someone other than an employee.”
S.C. v. Hilton Franchise Holding LLC, No. 2:23-cv-02037 (D. Nev. Nov. 12, 2024).
Nev. Rev. Stat. § 651.015(2)(a): 5 cases
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Rios, No. 2:23-cv-01108 (D. Nev. Sept. 29, 2025). “§ 651.015(2) (West 2025). 23 “If an injury is unforeseeable, then the innkeeper owes no duty, and the district court has no 24 occasion to consider the remaining elements of the plaintiffs cause of action .”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Racine v. PHW Las Vegas, LLC, 46 F. Supp. 3d 1028 (D. Nev. 2014). “Both parties have moved for summary judgment regarding the element of duty under NRS 651.015 (# 71 & # 75). Racine additionally seeks summary judgment on all remaining elements of NRS 651.”
Nev. Rev. Stat. § 651.015(2)(b): 1 case
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Nev. Rev. Stat. § 651.015(3): 10 cases
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014). “We note that under NRS 651.015, the district court was only tasked with determining whether such a crime was foreseeable, thereby imposing a duty on The Orleans.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014).
Nev. Rev. Stat. § 651.015(3)(a): 7 cases
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014). “We note that under NRS 651.015, the district court was only tasked with determining whether such a crime was foreseeable, thereby imposing a duty on The Orleans.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014).
Nev. Rev. Stat. § 651.015(3)(b): 7 cases
Est. of Smith ex rel. Smith v. Mahoney's Silver Nugget, Inc., 265 P.3d 688 (Nev. 2011). “: In this opinion, we consider the apparent disconnect between NRS 651.015’s limitation on innkeeper liability and our decision in Doud v.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Humphries Vs. New York-new York Hotel & Casino, LLC, 403 P.3d 358 (Nev. 2017). “NRS 651.015 precludes such liability unless the wrongful act that caused the injuries was foreseeable.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014). “We note that under NRS 651.015, the district court was only tasked with determining whether such a crime was foreseeable, thereby imposing a duty on The Orleans.”
Smith v. Coast Hotels & Casinos C/W 62589, No. 62153 (Nev. July 29, 2014).
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