Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al.

CourtDistrict Court, D. Nevada
DecidedSeptember 30, 2025
Docket2:20-cv-02123
StatusUnknown

This text of Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al. (Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al., (D. Nev. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 6 MARY JANE BEAUREGARD and JOHN Case No. 2:20-cv-02123-KJD-DJA HUGH SMITH, 7 ORDER on AMOUNT of PUNITIVE Plaintiffs, DAMAGES and MOTION to COMPEL 8 (ECF No. 182) v. 9 CLAYTON SAMPSON, et al., 10 Defendants. 11 12 After a three-day bench trial and supplemental briefing, the Court awarded damages and 13 entered judgment in the amount of $810, 445.47. (ECF Nos. 168, 169). The Court found that 14 punitive damages should be awarded and afforded the parties a hearing as required under NRS § 15 42.005. See Nev. Rev. Stat. § 42.005(3) (“If such damages are to be assessed, a subsequent 16 proceeding must be conducted before the same trier of fact to determine the amount of such 17 damages to be assessed.”). The hearing was held on February 11, 2025. (ECF No. 180). 18 Supplemental briefing was filed on March 31, 2025. (ECF Nos. 186, 187). The Court will now 19 determine the amount of punitive damages to be awarded. 20 Additionally, before the Court is Defendants’ Request to Compel Plaintiffs to Clarify 21 Propriety of Legal Research Expenses (ECF No. 182). Plaintiffs filed a response in opposition. 22 (ECF No. 183). 23 I. Standard for a Punitive Damages Award 24 The Court found that Plaintiffs are entitled to recover punitive damages from Defendants 25 pursuant to NRS § 42.005. (ECF Nos. 140, at 14, 16 and 168 at 10). NRS § 42.005 provides, in 26 relevant part: 27 “[I]n an action for the breach of an obligation not arising from contract, where is it 28 proven by clear and convincing evidence that the defendant has been guilty of oppression, fraud or malice, express or implied, the plaintiff, in addition to the 1 compensatory damages, may recover damages for the sake of example and by way of punishing the defendant.” 2 Nev. Rev. Stat. § 42.005(1). Once the district court makes a threshold determination that a 3 defendant’s conduct is subject to civil punishment, the decision to award punitive damages rests 4 entirely within the trier of fact’s discretion. Olivero v. Lowe, 995 P.2d 1023, 1028 (Nev. 2000). 5 In a bench trial the trier of fact is the presiding judge. Wood v. Safeway, Inc., 121 Nev. 724, 731 6 n. 19 121 P.3d 1026, 1031 (2005). 7 In Bongiovi, the Supreme Court of Nevada stated that the relevant considerations of a 8 fair, just, and reasonable punitive damage award are: the financial position of the defendant, 9 culpability and blameworthiness of the tortfeasor, vulnerability and injury suffered by the 10 offended party, the extent to which the punished conduct offends the public’s sense of justice and 11 propriety, and the means which are judged necessary to deter future misconduct of this kind. 12 Bongiovi v. Sullivan, 138 P.3d 433, 451 (2006). However, punitive damages may not exceed 13 three times the amount of compensatory damages if the amount of compensatory damages is 14 $100,000 or more. Countrywide Home Loans, Inc. v. Thitchener, 192 P.3d 243, 256 (Nev. 2008). 15 The Nevada Supreme Court regularly upholds punitive damages below this maximum 16 threshold in the face of claims that the awards violated due process. In Wyeth v. Rowatt, for 17 instance, a punitive damages award of less than three times the compensatory award was “well 18 within the accepted ratios.” 244 P.3d 765, 785 (2010). And in, Evans v. Dean Witter Reynolds, 19 Inc., the Nevada Supreme Court found that punitive damages award of $6 million was not 20 excessive because it was less than three times the compensatory damages award and “did not 21 annihilate” either defendant because the damages were a small portion of the net worths of either 22 party. 116 Nev. 598, 614, 5 P.3d 1043, 1053 (2000). 23 II. Factors the Court Considered in Awarding Punitive Damages Award 24 A. Discrepancies in Testimony 25 Discrepancies in the financial standing of Defendants has been caused by the 26 contradictory testimony of Defendants and the failure of Defendants to produce complete records 27 during discovery and in response to Court orders as described below. For example, Elisha 28 Sampson argued that a judgment involving fraud may affect her ability to sell life insurance 1 policies. (Trial Tr. 51:15–24, February 12, 2025). But when questioned by Plaintiffs’ counsel as 2 to whether she had been able to sell life insurance in the last year, Elisha testified that she had 3 done so. (Trial Tr. 65:66:2, February 12, 2025). Additionally, evidence was presented at the 4 January 2024 trial showing that Clayton Sampson filed a bankruptcy petition on December 14, 5 2018. (Plaintiff’s Trial Ex. 7). This was same date on which the Sampsons were discussing an 6 investment in EnvyTV with the Plaintiffs. In his bankruptcy petition, Clayton Sampson stated, 7 under penalty of perjury, that his estimated assets were worth between $0 and $50,000 as of 8 December 14, 2018. (ECF 163; Trial Tr. 203:19-204:7; Jan. 2, 2024). Later during trial, Clayton 9 Sampson contradicted the sworn statements made in his 2018 bankruptcy petition, testifying that 10 the value of his crypto holdings was “in the neighborhood” of $200,000 or $300,000 at the time 11 EnvyTV was formed in December 2018. (ECF 164; Trial Tr. 133:16-134:10; Jan. 4, 2024). 12 Clayton Sampson similarly provided contradictory testimony regarding his crypto 13 holdings at the February 2025 punitive damages hearing. On direct examination, Clayton 14 Sampson testified that his crypto account balance as of the date of the hearing was 1,273.31 and 15 this was the extent of his crypto holdings. (Trial Tr. 93:12-93:25; Feb. 12, 2025). Later, on cross- 16 examination, Clayton Sampson confirmed that his prior testimony regarding 1,273.31 in his 17 crypto account referred to the number of units of crypto held by Mr. Sampson, not the value of 18 his crypto holdings. (Trial Tr. 130:17-131:3; Feb. 12, 2025). Notwithstanding this testimony, 19 prior to the conclusion of the hearing, the Court asked Clayton Sampson to clarify his testimony 20 regarding his crypto holdings. In response to the Court’s inquiry, Clayton Sampson contradicted 21 his prior sworn testimony and testified that his reference to 1,273.31 in his crypto account 22 referred to the dollar value of his crypto holdings. 23 Further, in support of their purported inability to pay the judgment, Defendants 24 repeatedly offer conclusory arguments. When asked if a fraud judgment would affect his ability 25 to obtain employment, Clayton Sampson simply testifies “100 percent,” without explaining how 26 or if he had encountered any such difficulty. (Trial Tr. 87:2-11, February 12, 2025). And when 27 asked if he could pay an $800,000 judgment, Mr. Sampson testified “zero,” without providing 28 evidence or any factual support for this response, aside from the fact that he paid for an attorney 1 with a credit card. (Trial Tr. 87:10-21, February 12, 2025). 2 Thus, the conduct of Defendants during discovery, at trial, and during post-trial discovery 3 and hearings suggests that the Court should award a larger amount of punitive damages.

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Related

Olivero v. Lowe
995 P.2d 1023 (Nevada Supreme Court, 2000)
Wyeth v. Rowatt
244 P.3d 765 (Nevada Supreme Court, 2010)
Evans v. Dean Witter Reynolds, Inc.
5 P.3d 1043 (Nevada Supreme Court, 2000)
Bongiovi v. Sullivan
138 P.3d 433 (Nevada Supreme Court, 2006)
Countrywide Home Loans, Inc. v. Thitchener
192 P.3d 243 (Nevada Supreme Court, 2008)

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Bluebook (online)
Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/mary-jane-beauregard-and-john-hugh-smith-v-clayton-sampson-et-al-nvd-2025.