D'Angelo Law Library

Oh, how embarrassing! You walked in on me while I was doing some light reading.

Please, help yourself to cold brew, community, and maybe even a celebrity sighting if you’re lucky.

As you are all aware, October 27 has long been celebrated as "Navy Day" in the United States. The case of Hotels El Rancho v. Pray, 187 P.2d 568 (Nev. 1947), centers on a tragic accident resulting from a Navy Day celebration on October 27, 1945. On that date, the U.S. Navy conducted a celebratory bombing demonstration near the Hotel Last Frontier in Nevada. Bombs and rocket missiles were fired at a distant target, creating numerous craters and depressions across the open land used for the event. The next month, on November 25, 1945, the hotel hosted a cross-country horse race and treasure hunt for the public. At that time, the field still contained many holes left by the Navy demonstration.​

During the race, a 16-year-old participant was tragically was killed in the horse race when his horse encountered one of these concealed craters and fell, crushing the boy. Evidence showed the hotel manager and staff knew about the Navy demonstration and the resultant ground damage but failed to inspect or warn about the dangers before or during the race. Witnesses—including hotel employees—testified they never checked the course for safety until after the fatal accident.​

The Nevada Supreme Court found the hotel responsible for neglecting its duty to maintain safe premises and to warn guests of non-obvious hazards, especially when the risks stemmed from a dramatic public celebration on Navy Day. The decision awarded the victim’s mother damages and clarified that property owners must act when special events leave behind lingering, hidden hazards—even those tied to patriotic festivities.

This Navy Day, we remind our patrons to ride responsibly, and encourage all race hosts to fill in artilliary craters to the absolute best of your ability to avoid premises liability issues. Merry Navy Day, all!