Crazie Overstock Promotions, LLC v. State of North Carolina

CourtSupreme Court of North Carolina
DecidedJune 11, 2021
Docket345PA19
StatusPublished

This text of Crazie Overstock Promotions, LLC v. State of North Carolina (Crazie Overstock Promotions, LLC v. State of North Carolina) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crazie Overstock Promotions, LLC v. State of North Carolina, (N.C. 2021).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

2021-NCSC-57

No. 345PA19

Filed 11 June 2021

CRAZIE OVERSTOCK PROMOTIONS, LLC

v. STATE OF NORTH CAROLINA; and MARK J. SENTER, in his official capacity as Branch Head of the Alcohol Law Enforcement Division

On discretionary review pursuant to N.C.G.S. § 7A-31 of a unanimous decision

of the Court of Appeals, 266 N.C. App. 1 (2019), affirming, in part, and reversing and

remanding, in part, an order entered on 7 August 2018 by Judge Vince M. Rozier, Jr.,

in the Superior Court, Alamance County. Heard in the Supreme Court on 23 March

2021.

Morningstar Law Group, by Keith P. Anthony and William J. Brian, Jr., for plaintiff-appellant.

Joshua H. Stein, Attorney General, by Olga E. Vysotskaya de Brito, Special Deputy Attorney General; Ryan Y. Park, Solicitor General; and James W. Doggett, Deputy Solicitor General, for the State-appellees.

Edmond W. Caldwell, Jr., and Matthew L. Boyatt for North Carolina Sheriffs’ Association; Fred P. Baggett for North Carolina Association of Chiefs of Police; and Jim O’Neill for North Carolina Conference of District Attorneys, amici curiae.

ERVIN, Justice.

¶1 This case arises from an enterprise developed and operated by plaintiff Crazie

Overstock, LLC, which has sought in this litigation to enjoin enforcement measures CRAZIE OVERSTOCK V. STATE OF NORTH CAROLINA

Opinion of the Court

taken by the State and certain members of the State’s Alcohol and Law Enforcement

Division1 stemming from the belief that a Rewards Program encompassed within the

operation of Crazie Overstock’s enterprise violates various provisions contained in

Article 37 of Chapter 14 of the North Carolina General Statutes. For the reasons set

forth in more detail below, we modify and affirm the decision of the Court of Appeals.

¶2 Crazie Overstock sells discount goods, such as furniture, jewelry, kitchen

goods, movies, music, and electronics on its website and through licensed retail

establishments which are operated by independent owners. Although Crazie

Overstock’s customers have the ability to view the goods that are offered for sale, both

in these retail establishments and on Crazie Overstock’s website, the goods in

question may only be purchased through its website.

¶3 The retail establishments through which Crazie Overstock operates feature a

“showroom” in which samples of the goods that are available through Crazie

Overstock’s website are displayed. In addition, these retail establishments contain

computers, which Crazie Overstock refers to as “order stations,” that are connected

to the internet and through which customers have the ability to order products from

Crazie Overstock’s website. In addition, customers are also entitled to place orders

1 More specifically, Crazie Overstock has sought relief in this case against Mark J.,

Senter, individually and in his official capacity as Director of the Alcohol Law Enforcement Division, and Iris L. Redd, Kelly J. McMurray, Chris Poole, and Brian Doward, each of whom are agents of the Alcohol Law Enforcement Division; in their official and individual capacities. CRAZIE OVERSTOCK V. STATE OF NORTH CAROLINA

through Crazie Overstock’s website from any location at which an internet connection

is available. Crazie Overstock’s customers have the ability to either order goods

through the website using a credit card or to purchase electronic gift certificates at

retail establishments which the customer can use to purchase goods through Crazie

Overstock’s website.

¶4 The customers who purchase gift certificates at the retail establishments

through which Crazie Overstock operates pay $1.00 for each $1.00 of credit that is

available in connection with a particular gift certificate. Each customer who

purchases a gift certificate receives a receipt bearing a number which can be

registered with and credited to the customer’s account, which, in turn, can be accessed

using an individual username and password at an order station or on any device that

is connected to the Crazie Overstock website through the internet. In view of the fact

that the value of any gift certificate that a customer may purchase is not

automatically loaded into the customer’s account, gift certificates may be freely

transferred from the customer to other persons. Although customers may utilize gift

certificates to purchase goods through the Crazie Overstock website, any such

purchases involve separately stated shipping and handling charges that the customer

must cover using a credit card.

¶5 The portion of Crazie Overstock’s enterprise that underlies this case is known

as the Rewards Program and revolves around the use of gift certificates to play two CRAZIE OVERSTOCK V. STATE OF NORTH CAROLINA

electronic games. In order to play these games, a customer is required to obtain Game

Points by either (1) purchasing a gift certificate, with 100 Games Points being

provided to the customer for every $1.00 that the customer pays in order to purchase

that gift certificate; (2) “mailing a handwritten post card . . . contain[ing] the

[customer’s] name; address; city; state; zip code; age; date of the request for Game

Points; and the name and store address” at which the points are to be used; (3)

making an “in-store request from the cashier at a Retail Establishment’s point-of-sale

terminal”; or (4) “through the award of bonus Game Points by Retail Establishments

to customers who purchase certain amounts of gift certificates.” After obtaining the

required Game Points, the customer may use them to play the two electronic games.

¶6 In the first of the two electronic games, which consists of a game of chance

called the Reward Game, the customer is entitled to utilize Game Points for the

purpose of attempting to win Reward Points. The Reward Game features eighteen

reel-spinning games which are played on an electronic machine during which various

icons appear when the reel is spun. The results derived from playing the Reward

Game are “drawn randomly for each of the [eighteen] different Reward Games . . .

from a finite pool of possible results,” with “some results [being] associated with

Reward Points while others are not.” A customer who is successful in playing the

Reward Game receives a number of Reward Points equal to a multiple of the number

of Game Points which the customer utilized in order to play the Reward Game. In CRAZIE OVERSTOCK V. STATE OF NORTH CAROLINA

the event that the customer is unsuccessful during his or her attempts to play the

Reward Game, he or she is still awarded 100 Reward Points.

¶7 After playing the Reward Game, the customer is entitled to take the Reward

Points that he or she earned playing the Reward Game and utilize them to participate

in a game of skill called the Dexterity Test. The Dexterity Test involves the use of a

simulated stopwatch that counts from 0 to 1,000 and back at a rapid rate. During

the course of the Dexterity Test, the customer is allowed three attempts to stop the

stopwatch on a number as close to 1,000 as possible, with the customer being awarded

Dexterity Points based upon his or her best result. In the event that the customer

stops the simulated stopwatch at a point between 951 and 1,000, one-hundred percent

of the Reward Points that the customer used to play the Dexterity Test are converted

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