Appellate Court Upholds Ruling That Contracts Regarding Gambling Debts Are Void

In its non-precedential decision in the case of Dhaduk v. Patel, No. 576 MDA 2025 (Pa. Super. March 16, 2026 Kunselman, J., McLaughlin, J., and Lane, J.) (Mem. Op. by McLaughlin, J.), the Pennsylvania Superior Court sustained a trial court decision by Judge Terrence R. Nealon of the Lackawanna County Court of Common Pleas granting demurrers against a Plaintiff’s claims in a case arising out of a neurologist and his wife who sued an internist seeking to recover $700,000.00 for gambling losses that allegedly occurred at a Florida casino. 

The Plaintiffs alleged that the neurologist agreed to play blackjack on behalf of the internist with the express understanding that the internist would be responsible for any resultant gambling losses suffered by the neurologist in the process.

The Plaintiffs claim that the internist had not reimbursed the neurologist for $200,000.00 for chips that the neurologist purchased and lost and for an additional $500,000.00 that the neurologist obtained from his casino line of credit and ultimately lost playing black jack.

The Defendant internist filed demurrers against the Plaintiff’s claim of breach of contract, promissory estoppel, fraud, and unjust enrichment.

The Superior Court agreed with the trial court’s decision that a Pennsylvania statute held that gambling debts between private individuals were uncollectable and that any related contracts regarding gambling are void. The Superior Court upheld Judge Nealon’s ruling and agreed that Pennsylvania law precluded the recovery of the debt.

Anyone wishing to review a copy of this non-precedential decision may click this LINK.


Source: Article – “Court: Pair Can’t Recoup $700K Loan Friend Used For Gambling,” By Jim Lockwood of The Scranton Times (March 20, 2026).

Source of image:  Photo by Dusan Kipic on www.unsplash.com.  

You've Got To Know When To Hold 'Em, Know When to Fold 'Em

In the case of Dhaduk v. Patel, No. 2024-CV-5196 (C.P. Lacka. Co. March 31, 2025 Nealon, J.), the court granted demurrers against a Plaintiff’s claim in a case arising out of a neurologist and his wife who sued an internist seeking to recover $700,000.00 for gambling losses that allegedly occurred at a Florida casino.

The Plaintiffs allege that the neurologist agreed to play blackjack on behalf of the internist with the express understanding that the internist would be responsible for any resulting gambling losses suffered by the neurologist in the process. The Plaintiffs claimed that the internist had not reimbursed the neurologist for $200,000.00 for chips that the neurologist purchased and lost and for an additional $500,000.00 that the neurologist obtained from his casino line of credit and ultimately lost playing blackjack.

According to the Opinion, the Defendant doctor filed demurrers to the Plaintiff's claims of breach of contract, promissory estoppel, fraud, and unjust enrichment. 

Judge Terrence R. Nealon of the Lackawanna County Court of Common Pleas issued a lengthy Opinion outlining the current status of the law on these types of claims in the context of request for payment of gambling indebtedness.

Judge Nealon noted that, unlike other states with comparable statutes barring the collection of gambling debts and voiding any contracts for the payment of gambling indebtedness, the Pennsylvania legislature has never amended the Pennsylvania prohibitory statute in order to restrict its debt collection ban to illegal gambling or to create an exception for debts resulting from lawful gambling activities. 

Judge Nealon confirmed that the law in Pennsylvania remains that gambling debts between private individuals are uncollectible and that any related contracts regarding gambling are void.

As such, based upon the plain language of the applicable Pennsylvania statute, as well as a review of Florida’s corresponding statute, the court ruled that the Defendant could not be found liable in this case. Accordingly, the Defendant’s demurrers to all of the claims asserted by the Plaintiff were sustained.

Anyone wishing to review a copy of this decision may click this LINK.

Source of image: Photo by Anna Shvets on www.pexels.com.