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Hilton Hotels Corp. v. Butch Lewis Productions, Inc.

Citations: 808 P.2d 919; 107 Nev. 226; 1991 Nev. LEXIS 37Docket: 20458

Court: Nevada Supreme Court; April 3, 1991; Nevada; State Supreme Court

Narrative Opinion Summary

This case involves a contractual dispute between Hilton Hotels Corporation and Butch Lewis Productions, Inc., along with other parties, regarding a series of professional boxing events intended to determine an undisputed heavyweight champion. The contract, formed with Dynamic Duo, Inc., was based on the participation of Michael Spinks, an IBF champion. Following Spinks' forfeiture of his title, Hilton alleged that Dynamic Duo intentionally induced this outcome, breaching the contract and interfering with Hilton's expectations. After a jury verdict favoring the defendants, Hilton sought a new trial, alleging jury tampering and evidentiary errors. Although the court found no substantial prejudice from the alleged jury tampering, it identified an error in excluding crucial rebuttal evidence about Lewis's intentions, which was necessary to assess the breach of the implied covenant of good faith and fair dealing. The court concluded that while the jury instructions on the contract's ambiguity were proper, the exclusion of key evidence warranted a reversal and remand for a new trial. This decision underscores the importance of the implied covenant of good faith and fair dealing in contract enforcement, allowing Hilton to potentially recover damages despite the absence of an express contractual obligation for Spinks' participation.

Legal Issues Addressed

Contract Interpretation and Ambiguity

Application: The court allowed for interpretation of the contract beyond its literal terms, considering the parties' intentions and negotiations.

Reasoning: The jury was instructed to ascertain the parties' intentions based on the contract's language and surrounding circumstances, including negotiations and prior statements.

Evidentiary Error and New Trial

Application: The exclusion of rebuttal evidence regarding Lewis's intent was deemed erroneous, warranting a new trial on the breach of the implied covenant of good faith and fair dealing.

Reasoning: The trial court's refusal to allow Hilton to introduce this key rebuttal evidence, which directly addressed the core of Hilton's claims, warranted a reversal of the original judgment and a remand for a new trial.

Implied Covenant of Good Faith and Fair Dealing

Application: The court found that Dynamic Duo might be liable for breaching the implied covenant of good faith and fair dealing, as their actions could have undermined Hilton's contractual benefits.

Reasoning: Dynamic Duo had a legal duty not to interfere with Spinks' ability to participate in the Hilton events, despite lacking a contractual obligation to provide him as a contestant.

Jury Instructions on Contractual Obligations

Application: The court found that the jury was properly instructed that the ambiguous written contract did not obligate Dynamic Duo to produce Michael Spinks for all events.

Reasoning: The trial court was determined to have provided proper jury instructions, clarifying that the ambiguous written contract did not obligate Dynamic Duo to produce Michael Spinks for all events, as Hilton claimed.