BEAL v. PREMIER ENTERTAINMENT AC, LLC, 1:24-cv-07815

Plaintiff Roney Beal claims Bally’s Atlantic City Casino breached an aleatory contract by refusing to pay a $2.5 million jackpot allegedly won on a slot machine that displayed an error message after her win.
Defendant asserts that a machine malfunction (the “REEL TILT” error) voided any winnings, as per casino regulations and posted machine disclosures.
Plaintiff, after being denied payment and a meeting with management, filed a complaint with the New Jersey Division of Gaming Enforcement (DGE), whose investigation is ongoing.
Plaintiff’s Third Amended Complaint seeks the value of the alleged jackpot and related costs; Defendant removed the case to federal court and answered, raising the malfunction as an affirmative defense.
Defendant moved the court to administratively terminate (stay) the case until the DGE concluded its review, arguing that the outcome of the DGE investigation would be dispositive.
The Court granted Defendant’s motion, administratively terminating the case but not dismissing it, pending the DGE’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Stay pending DGE investigation	Beal claims she need not exhaust administrative remedies and the CCA does not preempt common law claims or govern private civil suits.	Bally’s argues that the DGE has primary jurisdiction and that the machine malfunction defense relies on CCA regulations, so the investigation is potentially dispositive.	Court grants stay, finding that the DGE/CCC has primary jurisdiction and outcome will simplify/dispose of case.
Prejudice from stay	Claims advanced age and health, plus unreasonable agency delay, cause unique prejudice.	Mere delay is not prejudice; stay will benefit both sides with clarity from DGE findings.	No undue prejudice found; stay proper.
Hardship to defendant if no stay	No significant argument.	Litigating before DGE decision risks redundant expense and uncertain law.	Denying stay would cause hardship to Defendant; weighs in favor of stay.
Whether stay will simplify trial	Case is a traditional breach of contract claim not requiring regulatory expertise.	CCA compliance/dispute central; DGE findings will narrow or resolve legal/factual disputes.	Stay will simplify or render trial unnecessary.

Bechtel Corp. v. Loc. 215, Laborers’ Int’l Union of N. Am., AFL-CIO, 544 F.2d 1207 (3d Cir. 1976) (stay of proceedings within district court’s discretion when there are parallel proceedings or related outcomes)
Landis v. North Am. Co., 299 U.S. 248 (1936) (federal court’s inherent power to stay proceedings for judicial efficiency)
Campione v. Adamar, Inc., 155 N.J. 245 (N.J. 1998) (primary jurisdiction of Casino Control Commission over casino matters)