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The enforcement of a debt incurred in the purchase of gambling chips in a state where gambling is perfectly legal does not violate the strong public policy of the State of Tennessee. Also, there is nothing in the Mississippi gambling laws that outrages the public policy of Tennessee. Therefore, a gaming contract between parties in Mississippi is enforceable in Tennessee.
Appellant Robinson Property Group, L.P., d/b/a Horseshoe Casino and Hotel operated a casino and hotel in Robinsonville, Mississippi. Appellee Yo Anne Russell, a Tennessee resident, approached appellant in March of 1995 to obtain a line of credit to enable her to issue drafts to the casino. Appellant extended to appellee a line of credit to enable her to issue drafts to the casino so that she could receive money to play the casino's slot machines. Appellee's bank refused to honor drafts due to insufficient funds after appellee lost money loaned to her at the casino. Appellant then sued appellee in Tennessee suit to collect payment of Mississippi gambling debt. The trial court granted summary judgment to appellee on the grounds the debt which arose from the gambling contract was unenforceable due to public policy considerations under Tenn. Code Ann. § 29-19-101. Appellant challenged the order.
Was the trial court correct in holding that the gambling contract violated Tennessee public policy?
The court reversed the judgment and remanded the case. The appellate court held that the gambling contract between the parties was enforceable in Tennessee as the contract at issue was a lawful gambling contract pursuant to Mississippi law. Moreover, there was nothing in the Mississippi gaming laws that outraged the public policy of Tennessee.