quotations and citations omitted); A.C. Shaw Const., Inc., 784 P.2d at 10 (special relationship required for tort-based claim but not for contract-based claim). Here, Risinger appears to plead only a tortious breach of the implied covenant. Although the FAC is ambiguous as to which theory Risinger’s wishes to proceed under, the parties briefed the matter assuming that the claim required a special relationship. SOC argues that Risinger failed to plead a special relationship, citing Nevada case law that refuses to declare all employment relationships automatically “special.” However, as SOC points out, breaches of employment relationships may under certain circumstances lead to tort liability under this theory. See, e.g., Shoen v. Amerco, Inc., 111 Nev. 735, 896 P.2d 469, 475-76 (1995) (<HOLDING>). Here, Risinger alleges sufficient facts to
holding that employer may use afteracquired evidence of resume fraud to avoid liability for breach of an employment contract if it can show that it had the power to void the contract due to reliance on material misrepresentations even where the employer was unaware of that power when the breach occurred holding that whatever direct corporate liability nordstrom had for fraud would be concurrent with director and officer liability since the directors and officers were liable for authorizing the fraud holding that there must be a tort distinguishable from or independent of the breach of contract in order for a party to bring a valid claim in tort based on a breach in a contractual relationship holding that an employment relationship allegedly terminated with fraud and malice may open employer to tort liability beyond the bounds of ordinary liability for breach of contract recognizing that the elements of a claim for breach of contract are 1 existence of a valid contract and 2 breach of the terms of that contract