Coughlin

During a convention at the Las Vegas Hilton, Navy Lieutenant Paula Coughlin was attacked by a group of men in a hotel hallway outside several convention-related hospitality suites. She sued several defendants, including the hotel and the organization which hosted the convention. A jury awarded her several million dollars in compensatory and punitive damages against the Las Vegas Hilton Corporation (“LVHC”) and Hilton Hotels Corporation (“HHC”). This award was subsequently reduced by the district court pursuant to Nev.Rev.Stat. § 42.005(1). LVHC and HHC (collectively, “Hilton”) appeal and Coughlin cross-appeals.

Coughlin’s cross-appeal presents an issue of Nevada law on which there is no controlling precedent of the Nevada Supreme Court. Because we resolve in Coughlin’s favor all of the issues raised by Hilton’s appeal, we must address Coughlin’s cross-appeal. We therefore exercise our discretion to certify to the Nevada Supreme Court the question Coughlin’s cross-appeal presents.

I. BACKGROUND

The infamous 1991 Tailhook Convention served as the stage for the despicable event that led to this lawsuit. Hosted by the Tail-hook Association (“Association”), the Tail-hook Convention…