Snowney v. Harrah’s Entertainment, Inc.

Frank Snowney (plaintiff) was a California resident who reserved a hotel room in Nevada operated by Harrah’s Entertainment, Inc. (Harrah’s) (defendant). Harrah’s agent informed Snowney that the room rate was $50 plus room tax. Harrah’s then also charged Snowney an additional three-dollar energy surcharge when he checked out. Harrah’s does not have any hotels, employees, or bank accounts in California. However, a significant percentage of Harrah’s business comes from California residents. Harrah’s advertises heavily in California, maintaining billboards in California and running print and radio ads in California. Harrah’s also operates a website that quotes room rates to visitors and permits visitors to make reservations at their hotels. The website advertises the hotels’ proximity to California and provides driving directions from California to these hotels. Snowney sued Harrah’s in California state court, alleging that Harrah’s improperly charged the energy fee without notice and seeking class-action status. Harrah’s filed a motion to quash the summons for lack of personal jurisdiction, claiming that the California state court lacked jurisdiction to impose rulings on Harrah’s for the Nevada dispute. The trial court granted the motion. The California Court of Appeal reversed, finding there was specific, personal jurisdiction over Harrah’s for this dispute. Harrah’s then petitioned the California Supreme Court for review.