Rahmani v. Resorts International Hotel, Inc.

In 1984 Najia Rahmani (plaintiff), a Virginia resident, traveled to Atlantic City, New Jersey, and gambled and lost a considerable sum of money at Resorts International Hotel (Resorts) (defendant). Resorts employees noticed Rahmani’s actions and observed that she appeared to be wealthy. After Rahmani returned to Virginia, Resorts repeatedly kept in communication with her for the next 13 years and induced her to come to its facility to gamble more. In 1990 Boardwalk Regency Corporation (Boardwalk) (defendant), another Atlantic City casino operator, also became aware of Rahmani’s propensity to gamble large sums of money and likewise began to encourage her to visit its facility. Boardwalk and Resorts sent Rahmani letters and promised that if she visited their casinos to gamble, they would send limousines to transport her and her guests, and she would receive free hotel accommodations, meals, and entertainment. The invitations, which recurred through 1997, succeeded in inducing Rahmani to the casinos, where she gambled and lost large sums of money. Over the course of 13 years, Rahmani claimed to have lost approximately $3.8 million. Rahmani filed a lawsuit against Resorts and Boardwalk in federal district court, claiming that her agreements to travel to the casinos to gamble were void under Virginia law, and that she was therefore entitled to rescission of those agreements and restitution of all amounts lost over the 13-year period. Rahmani argued that the relevant agreements consisted of the casinos’ offers to send her limousines and to provide meals, accommodations, and other entertainment in exchange for her gambling at their facilities. Her agreement to make the trips to their casinos, Rahmani argued, constituted acceptance of the casinos’ offers, thus making the agreements subject to Virginia law because the last act necessary to complete the contract occurred in Virginia. And under Virginia law, Rahmani argued, the contracts were void because they related to gambling. The casinos argued in response that the contracts were formed in New Jersey, where Rahmani placed her bets.