Wilson v. Mohegan Tribal Gaming Authority

7 Am. Tribal Law 448, 3 G.D.R. 98
CourtMohegan Gaming Disputes Trial Court
DecidedFebruary 26, 2008
DocketNo. GDTC-T-04-124-TBW
StatusPublished

This text of 7 Am. Tribal Law 448 (Wilson v. Mohegan Tribal Gaming Authority) is published on Counsel Stack Legal Research, covering Mohegan Gaming Disputes Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. Mohegan Tribal Gaming Authority, 7 Am. Tribal Law 448, 3 G.D.R. 98 (Mo. 2008).

Opinion

MEMORANDUM OF DECISION ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

WILSON, Judge.

The Plaintiff brought suit against the Defendant operator of the casino hotel alleging that he was assaulted and robbed while he was a guest at the hotel, and that his injuries were caused by the Defendant’s negligence in failing to provide proper security. The Defendant has moved for summary judgment. Because the court finds that there are issues of fact as to the nature and extent of the Defendant’s duties to the Plaintiff, and as to the [450]*450proximate cause of the Plaintiffs injuries, the motion is denied.

L

Facts and Claims of the Parties

The Plaintiffs complaint alleges that on February 17, 2004 he was a paid registered guest and business invitee at the Mohegan Sun Casino and Hotel, controlled, operated, and maintained by the Defendant, and that the Defendant was obligated to take reasonable efforts to provide for the Plaintiffs safety. He asserted that he was registered in a “Sky Suite” on the 30th floor of the Hotel and that such “Sky Suites” (those above the 26th floor) had separate elevators with appropriate security for such “YIP Guests.” The Plaintiff also claims that the Defendant knew or should have known that patrons such as the Plaintiff are at risk to be victims of assault and robbery because they often have large sums of cash and that they have been provided with complimentary alcohol. He also claims that the Casino and Hotel was the site of unlawful conduct including assaults, etc., and that it was reasonably foreseeable that a patron would be assaulted.

Plaintiff goes on to allege that on the night in question, he was returning to his suite when he was assaulted and robbed by a person who was not a registered guest, and that he suffered various injuries and loses.

Plaintiff alleges that his injuries and losses were proximately caused by the negligence of the Defendant in several respects, all relating to various failures of the Defendant to provide proper security. In this case the Defendant has not filed an answer to the complaint. But even if the court were to assume that the Defendant were to deny the operative provisions of the complaint, nevertheless, in deciding a Motion for Summary Judgment the trial court must view the evidence in the light most favorable to the Plaintiff, and the Defendant has the burden of showing the absence of any genuine issue of material fact. Monk v. Temple George Associates, LLC, 273 Conn. 108, 114, 869 A.2d 179, 184 (2005).

The Defendant has moved for summary judgment on the ground that there are no genuine issues of material fact in that the Defendant did not owe a legal duty to the Plaintiff as his injuries were not reasonably foreseeable; and that any of the Defendant’s alleged acts or omissions were not the proximate cause of the Plaintiffs injuries.

In its memorandum and affidavits in support of its motion the Defendant claims that it owed no duty to the Plaintiff because the general nature of the Plaintiffs injuries was not foreseeable and public policy considerations weigh heavily against imposing any such duty. The Defendant claims that it is not foreseeable that a patron would be assaulted while entering his guest room and that there had been no previous assaults or crimes.

The Defendant further argues that even if there were such a general duty, it did not extend to the particular circumstances here. In this regard the Defendant invites the court to “take judicial notice that there is no standard practice or procedure in the hotel industry which requires individuals to present a key or card to security personnel before entering an elevator. Hotels across the nation do not and have not required individuals to present a key or card to security personnel before entering an elevator.” Because the Plaintiff has alleged, and submitted some evidence to support, a more particular practice in this case, i.e., additional, or extra security for particular suites in this particular hotel, the Court declines to take any [451]*451such judicial notice. “Courts are not bound to take judicial notice of matters of fact. It is a discretionary function dependent on the nature of the subject mater, issues involved, and the apparent justice of the case.” Tait and Prescott, Tait's Handbook of Connecticut Evidence 93 (4th Ed.2008). The security practice or procedure of the Defendant at the “Sky Suites” above the 26th floor at the Mohegan Sun Casino Hotel is not a matter “within the knowledge of people generally in the ordinary course of human experience”; Ibid.; and therefore the Court will not take judicial notice of any such practice or procedure or absence thereof.

The Defendant finally argues that “the Plaintiff was simply a victim of a random crime and that the acts omissions of the Defendant were not the proximate cause of the Plaintiffs injuries.”

The affidavits submitted by the Defendant in support of its motion assert that the assault on the Plaintiff is the only incident of this nature that has been reported and that the Defendant had no knowledge of any other instances of such an assault; that the average daily patron count at the casino in February 2004 was 32,744, and the average daily hotel guest count at the hotel for February 2004 was 3,315; that the Defendant did not have any information that the Plaintiffs assailant was a suspect in any other assault at the casino; that on the evening in question the Defendant had five security officers and a supervisor'- working in the hotel; that the practice at the nearby Foxwoods Casino is not to check individuals for room key cards or ask if individuals are hotel guests as they enter hotel elevators; and that there are 37 floors in the hotel, of which 31 are occupied by guests, 71 bathrooms in the casino and related facilities, excluding the hotel, four parking garages, and seven parking lots.

The Defendant also submitted the Plaintiffs deposition testimony in which the Plaintiff described his version of the events.

Based on this evidence the Defendant argues that the assault on the Plaintiff was not foreseeable and that therefore the Defendant owed no duty to the Plaintiff; and that even if the Defendant owed a duty to the Plaintiff no act or omission of the Defendant was a proximate cause of the Plaintiffs injury. In support of it’s first argument the Defendant cites, inter alia, Jaworski v. Kiernan, 241 Conn. 399, 405, 696 A.2d 332 (1997); and in support of its argument that there is no issue of material fact as to proximate cause, Paige v. St. Andrew’s Roman Catholic Church, Corp., 250 Conn. at 25, 734 A.2d 85, and Medcalf v. Washington Heights Condominium Assn., 57 Conn.App. 12, 16-17, 747 A.2d 532, cert. denied, 253 Conn. 923, 754 A.2d 797 (2000).

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Related

Esposito v. Hospital of St. Raphael
111 A.2d 545 (Supreme Court of Connecticut, 1955)
Spencer v. Good Earth Restaurant Corporation
319 A.2d 403 (Supreme Court of Connecticut, 1972)
Buttry v. General Signal Corp.
68 F.3d 1488 (Second Circuit, 1995)
Barrett v. Danbury Hospital
654 A.2d 748 (Supreme Court of Connecticut, 1995)
Jaworski v. Kiernan
696 A.2d 332 (Supreme Court of Connecticut, 1997)
Paige v. Saint Andrew's Roman Catholic Church Corp.
734 A.2d 85 (Supreme Court of Connecticut, 1999)
Monk v. Temple George Associates, LLC
869 A.2d 179 (Supreme Court of Connecticut, 2005)
Medcalf v. Washington Heights Condominium Ass'n
747 A.2d 532 (Connecticut Appellate Court, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
7 Am. Tribal Law 448, 3 G.D.R. 98, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-mohegan-tribal-gaming-authority-mohegangct-2008.