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

District Court, D. Nevada·Decided September 30, 2025·No. 2:20-cv-02123·Unknown

Opinion

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

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

Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al. (Mary Jane Beauregard and John Hugh Smith v. Clayton Sampson, et al.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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)