Laurie Tsao v. Desert Palace, Inc.

Plaintiff-Appellant Laurie Tsao is a so-called “advantage” gambler — a professional gambler who uses legal techniques, such as card counting, to win at casino table games, especially blackjack. She was ar rested at Caesars Palace (a casino owned by the Defendant-Appellee Desert Palace) for trespassing and obstructing the duties of a police officer, and now challenges that arrest as unconstitutional and as constituting various common law torts. The District Court held that the casino’s security guard (non-party Clint Makeley) had probable cause to make a citizen’s arrest of Tsao for criminal trespassing; that Las Vegas Metro Police Officer Travis Crumrine, a Defendant-Appellee, had probable cause to arrest Tsao for obstructing the duties of a police officer; and that the probable cause determinations barred Tsao’s various claims for relief against Crumrine and Desert Palace. Tsao appeals those holdings and also the District Court’s grant of attorneys’ fees to Crumrine, as well as the award of certain costs to both defendants.

1. BACKGROUND

A. Casinos & “advantage” players

This case grows out of the high-stakes cat-and-mouse game played between advantage gamblers and…