Craigo v. Circus-Circus Enterprises, Inc.

OPINION

By the Court,

Steffen, J.:

After being assaulted and robbed in the elevator of the Circus-Circus parking garage, Robert Craigo filed an action seeking both compensatory and punitive damages against Circus-Circus Enterprises, Inc. (Circus-Circus). The trial court, sitting without a jury, awarded Craigo $45,000 in compensatory damages and $1,000,000 in punitive damages. The punitive award was based upon a determination by the trial judge that Circus-Circus had acted with “malice in fact.”1

*3Circus-Circus agrees that the issue of focus on appeal is the availability of a punitive damage award…