Carrie McCrea Hanlon is Senior Counsel in Tyson & Mendes’ Las Vegas office. Her practice focuses primarily on general civil liability, personal injury, premises liability, and automobile liability with an emphasis on traumatic brain injuries. Ms. Hanlon has been practicing in Las Vegas for 27 years and is licensed both in Nevada and California in state and federal courts.
Ms. Hanlon obtained a defense verdict in a traumatic brain injury case in which plaintiff’s counsel asked the jury to award $52 million dollars. In 2016, Ms. Hanlon obtained a defense verdict in a wrongful death case involving a fire in an apartment with no functioning smoke detectors. Ms. Hanlon has also obtained defense verdicts in multiple cases in which liability was adverse, such as rear-end automobile accidents.
Ms. Hanlon earned her J.D. in 1990 at California Western School of Law in San Diego where she served as Notes and Comments editor for the law review and was one of two to have articles published. Ms. Hanlon was also presented with the Faculty Award at graduation.
Ms. Hanlon is married to a music professor/trombone player who came to Las Vegas from Baltimore in 1968 to play on the strip. In her free time, Ms. Hanlon cares for Golden Retrievers who are too old to be adopted and nurtures them for the short balance of their lives.
Recent PostsNevada Howls for Howell
When the California Supreme Court issued its opinion in Howell v. Hamilton Meats 52 Cal.4th 541, 257 P.3d 1130, 129 Cal.Rptr.3D 325 (2011), Nevada defense attorneys were hopeful Nevada would follow California’s example and prohibit plaintiff’s lawyers from introducing evidence of medical bills that had been partially or totally forgiven by medical providers. The defense bar was hopeful the case of Tri-County Equip. and Leasing, LLC v. Klinke, 1268 Nev. Adv. Op. 33, 286 P.3d 593 (2012), would be the vehicle by which Nevada would adopt the Howell precedent. This was not to be.Punitive Damages are Not Insurable? Welcome to Fabulous Las Vegas!
When a client asks “if we get hit for punitive damages, will my insurance cover it?” it’s tempting to offer the knee jerk response, “There is no insurance coverage for punitive damages. It would violate public policy to do otherwise.” But in Nevada, the correct answer is “It depends.” Leave it to Las Vegas!The Latest Wrinkle in Nevada Medical Liens
It is bad enough in Nevada plaintiff gets to board the actual amount billed by providers for medical treatment as opposed to the amount received. It is doubly bad the number can be the amount put on a lien with the medical provider, as the lien number is typically higher than the amount would have been if billed through an insurance carrier. Before a provider will take the case on a lien, it often seeks details to evaluate the risk, since if plaintiff does not win, the provider does not get paid. The doctor will ask about the amount of coverage, whether liability is disputed and whether their potential patient has a history of prior accidents or preexisting issues. At least, at time of trial, defense counsel is allowed to ask whether the patient treated on a lien to attempt to establish bias due to the doctor having a financial investment in the outcome of the case. Khoury v. Seastrand, 377 P.3d 81, 132 Nev. Adv. Op. 52 (2016).Nevada Now Has a Court of Appeals! How Does it Work?
Until 2014, all appeals from decisions of the Nevada District Courts were heard by the Nevada Supreme Court. (Nevada is broken into eleven judicial districts; Clark County, which includes Las Vegas, is in the Eighth Judicial District.) The case of Figueroa v. IDS Prop. and Cas. Ins. Co. provides a good example of how the trial, appellate and supreme court works in Nevada. It is what is known as a “push down” model.COWABUNGA: Nevada Alter Ego Liability
On November 22, 2017 the Nevada Supreme Court held that managers of a limited liability corporation (LLC) may be subject to suit for personal negligence as tortfeasors under an alter ego theory of liability.
In the case of Gardner v. Henderson Water Park, LLC dba Cowabunga Bay Water Park, 133 Nev. Adv. Op 89, the Gardners’ minor child suffered injuries resulting from a near-drowning at Cowabunga Bay Water Park in Henderson, Nevada. The Gardners filed suit against Henderson Water Park, LLC dba Cowabunga Bay Water Park and its two managing members, West Coast Water Parks, LLC and Double Ott Water Holdings, LLC. The 7 managers of West Coast and Double Ott LLCs have an ownership interest in, or manage, the member-LLCs and also serve on the management committee governing the water park itself.