In McKee v. Isle of Capri Casinos, Inc., a penny slot displayed a bonus award of $41,797,550.16. The Iowa Supreme Court held that the patron was entitled to just $1.85, because the game’s approved rules—not the flashing screen—formed the contract between the player and the casino.
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The Contract Controls
She won $1.85. The screen showed $41,797,550.16.
The Iowa Supreme Court ruled that the game’s rules, not the screen, formed a contract between the patron and the casino. Those rules contained the clause “malfunction voids all pays and plays,” as an Iowa appellate brief later quoted. Because she failed to prove she satisfied the paytable conditions for the bonus, the casino owed her nothing beyond the 185 credits. The court also threw out her promissory estoppel, equitable estoppel, and consumer-fraud claims. It stressed that she could not show an ascertainable loss—the malfunction display does not create a right to the flashed amount. The result: a machine’s visual promise is legally silent if the code says otherwise.
The Screen Is Not the Paytable
Three years later, Katrina Bookman watched a penny slot at Resorts World New York City display roughly $43 million. The New York State Gaming Commission investigated and, per NBC New York, called it a clear display malfunction. The casino told the Associated Press, via CBS News, that the malfunction voided all plays, so it could not pay even the $6,500 maximum. The warning “malfunction voids all pays and plays” was apparently printed on the cabinet, a standard U.S. notice.
Both cases teach the same hard lesson. A slot machine’s screen is a piece of glass, not a contract. The only enforceable promise is the paytable approved by the regulator and embedded in the game’s programming. If the paytable says a bonus requires a specific symbol combination, a screen that freezes on a random number is not a win. It is an error.
When Malfunction Clauses Matter
Timing is everything. In Griggs v. Harrah Casino IGT, a Louisiana appellate court explained that the phrase “any malfunction voids all plays and pays” does not apply to a play that has already finished or to a jackpot legitimately won before the equipment broke. The court drew a line: a malfunction that occurs after a valid transaction cannot retroactively erase the win, but one that prevents the game from ever reaching a valid payout is fatal to the claim.
Think of it this way: if a machine pays a jackpot and then powers off, the casino still owes the money. But if the reels stop on a nonsensical pattern because of an internal fault, the display is meaningless. The Griggs ruling ensures the clause is not a universal eraser; it only blocks claims never perfected under the game’s approved logic.
The Regulator’s Gate and the Missing Paper Trail
Anyone who sees a gargantuan jackpot and gets told it was a malfunction must begin with the state gaming regulator, not a courtroom. In Iowa, the Supreme Court’s entire analysis depended on the regulator-approved game rules. In New York, the Gaming Commission issued its own conclusion, shutting down any attempt to sue for the screen amount. But the paper trail that a complainant must follow is surprisingly faint.
The full Iowa opinion is not easily found online. The New York commission’s formal ruling sits in no public docket; the record is news reports quoting a spokesperson. The exact complaint form, investigation steps, and judicial-review statute are not laid out in a player-accessible document. No other state has published a comparable malfunction ruling in an easily retrievable way.
The lesson from both jurisdictions is blunt: for a player facing this, the only move that matters is securing a copy of the approved paytable and filing a formal complaint with the state gaming commission. The case law draws a bright line: what a machine shows on its screen is not what the casino is authorized to pay. What remains unresolved is how a complainant gets from a malfunction notice to a written commission ruling that a court can review. That path, even today, remains poorly lit.