Nev. Rev. Stat. § 11.190
Limitations of actions: the cases that interpreted this section
504 citing cases reviewed of 656 in the citation index: 348 interpreted the section (annotated below), 156 cited it only in passing. Cases filed after 2026-03-12 may not have been reviewed yet.
Have a situation under Nev. Rev. Stat. § 11.190?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Written-contract and foreclosure claims
Section 11.190(1)(b) supplies a six-year limitations period for judicial foreclosure claims founded on a written contract.
Ramanathan v. Bank of America, N.A. · filed 2021-09-30(1)(b)
BONY’s judicial foreclosure claim is untimely. The limitation period for a judicial foreclosure is six years. Facklam v. HSBC Bank USA for Deutsche ALT-A Sec. Mortg. Loan Tr., 401 P.3d 1068, 1071 (Nev. 2017) (en banc) (citing Nev. Rev. Stat. § 11.190(1)(b) as the limitation period for an action on a written contract). When the debtors were discharged in April 2009, BONY knew or should have known that it would not be able to recover additional payments or a deficiency judgment from the debtors and that its only remedy was to resort to its security interest in the property. At that point, BONY knew or should have known that it had six years to pursue a judicial foreclosure based on a breach of the note and deed of trust. BONY’s judicial foreclosure claim thus accrued in April 2009 (when the debtors were discharged), or at the latest in October 2009 (when the bankruptcy court lifted the stay).Read the full opinion on CourtListener →
Tolling and equitable exceptions
Section 11.190(4), including subsection (4)(c), sets a two-year period for covered tort claims; a nonmandatory citizen-review proceeding does not toll that period under Shively, and equitable tolling requires diligence and an extraordinary circumstance.
WILSON v. LAS VEGAS METRO. POLICE DEP'T · filed 2021-11-18(4), (4)(c)
NRS 11.190(4) provides a two-year limitations period for an action for battery or false imprisonment, or for "an action to recover damages for injuries to a person . . . caused by the wrongful act or neglect of another." NRS 11.190(4)(c), (e). That period begins to run "when the wrong occurs and a party sustains injuries for which relief could be sought." ... Accordingly, we conclude that the CRB proceeding did not toll the statute of limitations pursuant to Shively. ... We recently established the threshold requirements for equitable tolling of NRS 11.190(4)(as limitations period: (1) the plaintiff exercised diligence in pursuing his or her claims, and (2) some extraordinary circumstance prevented the plaintiff from bringing a timely action.2 See Fausto, 137 Nev., Adv. Op. 11, 482 P.3d at 682. ... Thus, we conclude that Wilson failed to establish that an extraordinary circumstance prevented him from timely asserting his claims and the district court properly determined that the statute of limitations barred Wilson's complaint.Read the full opinion on CourtListener →
Two-year personal-injury and search claims
Section 11.190(4)(e) supplies a two-year limitations period for IIED and § 1983 search-and-seizure claims, with accrual tied to the wrongful act or other accrual of the cause of action; the court did not decide whether the discovery rule applies.
Brown v. Tromba · filed 2022-01-24(4)(e)
The limitation period for Brown’s search and seizure claim is two years. Nev. Rev. Stat. § 11.190(4)(e); see also Wallace v. Kato, 549 U.S. 384, 387 (2007) (limitation period for § 1983 claim is that for personal injury torts in the state in which the cause of action arose). “A cause of action for illegal search and seizure accrues when the wrongful act occurs . . . even if the person does not know at that time that the search was warrantless.” ... The search and seizure underlying Brown’s claim occurred on September 25, 2016. Brown’s cause of action began accruing that day. ... I therefore deny his motion for leave to amend to include this claim because it is futile as time-barred.Read the full opinion on CourtListener →
Section 11.190(4)(e) provides a two-year statute of limitations for personal-injury claims, including § 1983 actions in Nevada.
Love v. The State of Nevada · filed 2023-10-11(4)(e)
“In Nevada, the statute of limitations for personal injury claims, and therefore § 1983 actions, is two years.” Id. (citing Nev. Rev. Stat. § 11.190(4)(e)).Read the full opinion on CourtListener →
Section 11.190 imposes a two-year limitations period on personal injury claims, including IIED claims; an IIED claim that relates back to the original complaint is not time-barred under that period.
McCart-Pollak v. On Demand Direct Response LLC · filed 2023-12-06
Personal injury claims, including IIED claims, are subject to a two-year statute of limitations. NRS 11.190. ... But an “amendment to a pleading relates back to the date of the original pleading when[] . . . the amendment asserts a claim or defense that arose out of the conduct, transaction, or occurrence set out—or attempted to be set out—in the original pleading.” ... Because Plaintiff’s IIED claim likely relates back to the date of the Original Complaint, it is not time barred.Read the full opinion on CourtListener →
Section 11.190(4)(e) provides a two-year statute of limitations for applicable personal-injury claims, including the § 1983 claim at issue here.
Rios v. Bryan · filed 2024-09-30(4)(e)
The applicable Nevada statute of limitations is two years. See Rosales-Martinez v. Palmer, 753 F.3d 890, 895 (9th Cir. 2014) (citing Nev. Rev. Stat. § 11.190(4)(e)). The Court applies this statute of limitations here.Read the full opinion on CourtListener →
Section 11.190(4)(e) supplies a two-year statute of limitations for § 1983 actions brought in Nevada.
Velasco v. Balaam · filed 2024-12-19(4)(e)
The applicable statute of limitations for § 1983 actions brought in Nevada is two years.Read the full opinion on CourtListener →
Section 11.190(4)(e) imposes a two-year statute of limitations on personal injury claims in Nevada.
Montgomery v. West · filed 2023-04-17(4)(e)
A two-year statute of limitations applies in this Bivens action, and it expired long ago. “Federal law determines when a Bivens claim accrues, [but] the law of the forum state determines the statute of limitations for such a claim.” Papa v. United States, 281 F.3d 1004, 1009 (9th Cir. 2002) (superseded by statute). “A Bivens claim accrues when the plaintiff knows or has reason to know of the injury.” W. Ctr. for Journalism v. Cederquist, 235 F.3d 1153, 1156 (9th Cir. 2000). Bivens claims are subject to the forum state’s statute of limitations for personal injury claims. Id. at 1156. In Nevada, the statute of limitations for personal injury claims is two years. Nev. Rev. Stat. § 11.190(4)(e).Read the full opinion on CourtListener →
Discovery-based accrual for deceptive practices
Section 11.190(1)(b)'s limitations period is tolled under Nevada's discovery rule until the injured party discovers or reasonably should have discovered the facts constituting the cause of action.
Scammell · filed 2025-11-04(1)(b)
Plaintiff alleges that it did not know about the Voyager Health judgment until January 2022 due to Defendant’s concealment, thus the Court finds that the statute of limitations began to accrue at that time.Read the full opinion on CourtListener →
Taking, detaining, or injuring personal property
Section 11.190(3)(c) imposes a three-year limitations period on an action for taking, detaining, or injuring personal property, including a takings claim based on the value of personal property.
Nev. Yellow Cab Corp. v. State · filed 2022-12-01(3)(c)
This claim falls squarely within NRS 11.190(3)(c), which, again, governs "[a]n action for taking, detaining or injuring personal property." (Emphasis added.) As the district court correctly held, appellants' claims were time-barred by NRS 11.190(3)(c) because those claims alleged a taking of their personal property.Read the full opinion on CourtListener →
Subsection 11.190(5) provides a one-year limitations period for claims against an officer arising from unlawful seizure of property.
Rogers v. LVMPD (Police Department) · filed 2023-09-30(5)
Under Nevada law, the statute of limitations for bringing a claim against a police officer for the unlawful seizure of property is one year.Read the full opinion on CourtListener →
Statute of limitations
Section 11.190 requires actions founded on written instruments to be commenced within six years and fraud actions to be filed within three years after discovery.
In re: Armin Dirk Van Damme · filed 2023-04-12(1)(b), (3)(d)
NRS 11.190(1)(b) provides that: “An action upon a contract, obligation or liability founded upon an instrument in writing . . .” must be commenced within six years. ... NRS 11.190(3)(d) provides that fraud actions must be filed within three years of discovery.Read the full opinion on CourtListener →
Section 11.190(3)(d) provides a three-year limitations period for fraud or mistake claims running from discovery, subsection (2)(c) provides a four-year period for implied-covenant claims, and subsection (3)(c) provides a three-year period for injury-to-personal-property claims.
United States of America v. Bank of George · filed 2022-12-13(3)(d), (2)(c), (3)(c)
The first and second counterclaims for misrepresentation are subject to a three-year limitation period, which begins when the aggrieved party discovers the facts constituting the fraud or mistake. Nev. Rev. Stat. § 11.190(3)(d). ... The Bank’s sixth amended counterclaim for breach of the implied covenant of good faith and fair dealing has a four-year limitation period. Nev. Rev. Stat. § 11.190(2)(c); Schumacher v. State Farm Fire & Cas. Co., 467 F. Supp. 2d 1090, 1094-95 (D. Nev. 2006). ... “Claims for intentional interference with prospective business advantage [. . .] are claims for injury to personal property and are therefore subject to the three-year statute of limitations in NRS 11.190(3)(c).” Stalk v. Mushkin, 199 P.3d 838, 844 (Nev. 2009).Read the full opinion on CourtListener →
Section 11.190(4)(e) imposes a two-year limitations period for personal-injury claims, and subsection (4)(c) imposes a two-year period for defamation claims.
Mitchell v. Nye County, Nevada · filed 2023-02-27(4)(e), (4)(c)
Federal courts apply the forum state’s personal injury statute of limitations to § 1983 claims. ... In Nevada, the limitation period for personal injury is two years. Nev. Rev. Stat. § 11.190(4)(e). ... Thus, to the extent that any claim is based on Ryhal and other Nye County officials visiting the Mitchells’ property in July 2017, it accrued in 2017. Because this suit was filed in 2020, any claim based on those visits is barred by the two-year limitation period. ... The limitation period for defamation is two years. Nev. Rev. Stat. § 11.190(4)(c).Read the full opinion on CourtListener →
Subsection (1) requires breach-of-contract claims to be filed within six years of the breach, while subsection (4)(c) requires slander-of-title claims to be filed within three years of the deed’s recording.
Ticey v. Federal Deposit Insurance Corporation · filed 2023-03-31(1), (4)(c)
Nevada law requires breach of contract claims to be brought within six years of the breach. Nev. Rev. Stat. § 11.190(1). ... Here, Plaintiffs bring their breach of contract claim far more than six years after they signed the Loan Agreement which clearly spelled out the limitation on conversions from a variable to a fixed rate. Plaintiffs identify no reason why they could not have identified this feature of the Loan Agreement within the statute of limitations. And while Plaintiffs allege they only discovered this feature in 2021, they provide no reason why they could not have discovered this provision earlier with diligence. The Court GRANTS the Motion and DISMISSES this claim WITH PREJUDICE because it is time-barred. ... Additionally, Plaintiffs’ claim is untimely. Under either California or Nevada law, the claim must be brought within 2 or 3 years, respectively, of the recording of the deed. Cal. Code Civ. P. § 338(g); NRS 11.190(4)(c). The deed here was record in 2007, and Plaintiffs’ claim filed in 2022 is untimely. This is separate and independent basis on which the Court dismisses this claim.Read the full opinion on CourtListener →
Section 11.190(4)(e) supplies a two-year limitations period for these claims, which accrued more than two years before the complaint was filed.
Tretiak v. Del Papa · filed 2001-11-13(4)(e)
The district court did not err when it dismissed Tretiak’s claims arising from the state disciplinary proceedings in early 1997, the ALJ’s decision or the adoption of that decision in mid-1997, and the state’s issuance of a press release in June 1997. These claims were barred by the statute of limitations because they accrued more than two years before Tretiak filed his complaint on November 5,1999.Read the full opinion on CourtListener →
Two-year statute of limitations for § 1983 claims
Section 11.190(4)(e) imposes a two-year limitations period on § 1983 claims in Nevada.
Hamilton v. Jasperson · filed 2023-03-14(4)(e)
Second, the district court correctly dismissed Mr. Hamilton’s claims against Nye County as untimely. A two-year statute of limitations applies. See Nev. Rev. Stat. § 11.190(4)(e); Perez v. Seevers, 869 F.2d 425, 426 (9th Cir. 1989) (per curiam) (holding that Nevada’s two-year statute of limitations in Nevada Revised Statute section 11.190(4)(e) applies to § 1983 claims).Read the full opinion on CourtListener →
Section 11.190 provides a two-year limitations period for § 1983 claims.
Rodriguez v. Well Path · filed 2023-03-29
Finally, regarding the timeliness of the claims against Meisner, the Court does not see how the claim is untimely. The Court agrees with the moving Defendants that the limitations period for Plaintiff’s § 1983 claims is two years viz. NRS 11.190. Plaintiff alleges that Meisner met with Plaintiff in December of 2018 and thereafter failed to provide care to Plaintiff. Plaintiff describes this conduct in Plaintiff’s original complaint in this case, which was filed on December 3, 2019. (ECF No. 1-1 at 12.) The subsequent amendments to the complaint relate back since this conduct was set out in the original complaint. Fed. R. Civ. P. 15(c)(1)(B). Plaintiff’s claim against Meisner is timely.Read the full opinion on CourtListener →
Section 11.190(4)(e) provides a two-year limitations period for §1983 claims in federal actions in Nevada, running from accrual.
Mwithiga v. Office J Pierce · filed 2024-08-01(4)(e)
The statute of limitations for §1983 claim must be filed within two years of the date when the cause of action accrued, as provided by NRS 11.190(4)(e), and applied in federal actions in Nevada.Read the full opinion on CourtListener →
Section 11.190(4)(e) supplies Nevada’s two-year limitations period for § 1983 personal-injury claims.
Posey v. Perez · filed 2025-03-10(4)(e)
The applicable statute of limitations for a cause of action under 42 U.S.C. § 1983 is the statute of limitations established by the forum state for personal injury torts. ... In Nevada, that is two years. See NRS § 11.190(4)(e).Read the full opinion on CourtListener →
Subsections (4)(e) and (4)(c) impose two-year statutes of limitations for intentional infliction of emotional distress and defamation claims, respectively.
Fan v. Jiang · filed 2025-06-23(4)(e), (4)(c)
In Nevada, IIED claims must be brought within two years. See NRS § 11.190(4)(e); ... Defamation claims are also subject to a two year statute of limitations in Nevada. See NRS § 11.190(4)(c).Read the full opinion on CourtListener →
Limitations period for breach of fiduciary duty
Section 11.190(3)(d) imposes a three-year limitations period on breach-of-fiduciary-duty claims treated as fraud, with accrual delayed until the injured party knew or reasonably should have known the facts giving rise to the breach.
Gaines v. Keasberry · filed 2023-07-25(3)(d)
Outside the context of the attorney-client relationship, a “breach of fiduciary duty is fraud” and is therefore subject to a three-year statute of limitation. Nev. State Bank v. Jamison Fam. P’ship, 801 P.2d 1377, 1382 (Nev. 1990) (per curiam) (citing Nev. Rev. Stat. § 11.190(3)(d)). “However, the statute of limitation will not commence to run until the aggrieved party knew, or reasonably should have known, of the facts giving rise to the breach.” Id.Read the full opinion on CourtListener →
Four-year limitations period for intentional interference and unjust enrichment
Section 11.190(2)(c) gives intentional-interference and unjust-enrichment claims a four-year limitations period.
Razaghi v. Razaghi Development Company, LLC · filed 2023-09-30(2)(c)
Under Nevada law, the statute of limitations for intentional interference and unjust enrichment is four years.Read the full opinion on CourtListener →
Subsection (2)(c) supplies a four-year limitations period for unjust-enrichment claims, and the discovery rule applies when determining whether that period has run.
Winkler · filed 2026-01-05(2)(c)
Defendants next argue that plaintiff’s unjust enrichment claim is time barred by NRS 11.190(2)(c). ... “The statute of limitation for an unjust enrichment claim is four years. In re Amerco Derivative Litig., 252 P.3d 681, 703 (Nev. 2011) (citing NRS 11.190(2)(c)). ... However, in In Re Amerco Derivative Litig., the Nevada Supreme Court held that the discovery rule applies when analyzing a claim of unjust enrichment and reversed the district court for dismissing the case without making a factual determination on whether the statute of limitations had run. ... This court is bound by this rationale and, thus, plaintiff’s unjust enrichment claim survives the motion to dismiss stage.Read the full opinion on CourtListener →
Judgment validity period
Section 11.190(1)(a) provides that a judgment remains valid for six years before renewal is required, with the limitations period running from the last transaction and expiring six years later.
Miller v. Crisis Collection Management, LLC · filed 2023-11-20(1)(a)
In Nevada, a judgment is valid for six years before it must be renewed. Nev. Rev. Stat. § 11.190(1)(a). ... The limitations period begins on the date of “the last transaction or the last item charged or last credit given,” or at the time the last overdue payment is made, and expires six years later. Id. §§ 11.190(1)(a), 11.200, 17.150(2); see also Davidson v. Davidson, 382 P.3d 880, 885 (Nev. 2016).Read the full opinion on CourtListener →
Fraud, statutory-liability, and false-imprisonment limitations
Section 11.190(3)(d) sets a three-year limitations period for fraud claims under Nevada law.
Williams v. Bank of America, N.A. · filed 2017-08-16(3)(d)
The district court properly dismissed Williams’ Truth in Lending Act (“TILA”), Real Estate Settlement Procedures Act (“RESPA”), intentional misrepresentation, and rescission based upon fraud claims because these claims are barred by the applicable statutes of limitations and Williams failed to plead facts demonstrating that equitable tolling should apply. See 12 U.S.C. § 2614 (RESPA claims under 12 U.S.C. § 2607 are subject to a one-year statute of limitations); 15 U.S.C. § 1640(e) (TILA damages claims are subject to a one-year statute of limitations); Nev. Rev. Stat. § 11.190(3)(d) (fraud claims under Nevada law are subject to a three-year statute of limitations); see also Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034, 1045 (9th Cir. 2011) (federal standard for equitable tolling); Howard v. Howard, 239 P.2d 584, 588-89 (Nev. 1952) (fraud claim accrues under Nevada law when the defrauded person knows, or could have known through proper diligence, of the fraud).Read the full opinion on CourtListener →
NRS 11.190(3)(d) gives fraud claims a three-year limitations period tolled until the claimant knew or had reason to know of the violation, (3)(a) gives statutory-liability claims three years, and (4)(c) gives false-imprisonment claims two years subject to equitable tolling.
Scrase v. Scrase · filed 2023-12-06(3)(d), (3)(a), (4)(c)
The statute of limitations for fraud is three years. ... The Nevada Supreme Court has concluded that fraud actions are tolled under NRS 11.190(3)(d) until the party bringing the claim “knew or had reason to know that its rights had been violated.” ... Under NRS 11.190(3)(a), actions “upon a liability created by statute”—like the NRS 41.1395 elder abuse claim—must be brought within three years. ... NRS 11.190(4)(c) provides a two-year limitations period for an action for false imprisonment. ... The Nevada Supreme Court has employed the equitable tolling analysis when considering the two-year limitation in NRS 11.190(4)(c).Read the full opinion on CourtListener →
Section 11.190(4)(c) imposes a two-year limitations period on defamation claims.
Aragon v. Black · filed 2023-12-11(4)(c)
Nevada applies a two-year statute of limitations to defamation claims. Nev. Rev. Stat. § 11.190(4)(c).Read the full opinion on CourtListener →
Section 11.190(4)(e) provides a two-year limitations period for this personal-injury § 1983 claim, subject to equitable tolling.
Swallow v. Elko County · filed 2023-12-27(4)(e)
Federal courts apply state statutes of limitations to § 1983 claims, Lockett v. County of Los Angeles, 977 F.3d 737, 740 (9th Cir. 2020), and Nevada’s statute of limitations for claims such as Mr. Swallow’s is two years, NRS 11.190(4)(e); see also Rosales-Martinez v. Palmer, 753 F.3d 890, 895 (9th Cir. 2014) (“in the absence of a federal provision for § 1983 actions, the analogous [Nevada] state statute of limitations for personal injury claims applies.”); Perrez v. Seevers, 869 F.2d 425 (9th Cir. 1989).Read the full opinion on CourtListener →
Section 11.190(2)(c) provides a four-year limitations period for liabilities not founded on a written instrument, while subsection (3)(a) provides a three-year period for claims under Nev. Rev. Stat. § 686A.310, running from the triggering event.
U.S. Bank National Association v. Fidelity National Title Group, Inc. · filed 2024-03-25(2)(c), (3)(a)
A bad faith tort claim is controlled by the four-year statute of limitations covering actions upon a liability not founded upon an instrument in writing. Schumacher v. State Farm Fire & Cas. Co., 467 F. Supp. 2d 1090, 1094 (D. Nev. 2006); see Nev. Rev. Stat. § 11.190(2)(c). ... “A claim based on violation of Nev. Rev. Stat. § 686A.310 must be filed within three years of the triggering event.” Williams v. Travelers Home & Marine Ins. Co., 740 F. App’x 134 (9th Cir. 2018) (citing NRS § 11.190(3)(a)). The limitations period begins when the insurer formally denies the claim.Read the full opinion on CourtListener →
Section 11.190 provides a two-year limitations period for personal-injury claims.
Herrera v. Florence McClure Women's Correctional Center · filed 2024-07-17
The personal-injury statute of limitations in Nevada is two years.Read the full opinion on CourtListener →
Subsection (3) gives an Unfair Claims Practices Act claim under NRS 686A.310 a three-year limitations period, running in this insurance context from the date of claim denial.
Lang-Black v. AAA Life Insurance Company · filed 2024-08-16(3)
An Unfair Claims Practices Act claim under NRS 686A.310 has a three-year statute of limitations. NRS 11.190(3). Generally, “a cause of action accrues when the wrong occurs and a party sustains injuries for which relief could be sought.” Petersen v. Bruen, 792 P.2d 18, 20 (Nev. 1990). In the insurance context, claims accrue for statute of limitations purposes from the date of claim denial. State Farm Mut. Auto. Ins. Co. v. Fitts, 99 P.3d 1160, 1162 (Nev. 2004). ... Because Plaintiff's NRS 686A.310 claim accrued on the date Defendant denied her life benefits, Plaintiff's claim is untimely.Read the full opinion on CourtListener →
Application to nonjudicial foreclosures
Section 11.190's six-year limitations periods apply only to judicial actions and do not bar a nonjudicial foreclosure.
Radecki v. Bank of America, N.A. · filed 2024-03-19
The problem with this argument is that NRS 11.190 does not appear to apply to the nonjudicial foreclosure at issue. “NRS 11.190 serves only to bar judicial actions; thus, they are inapplicable to nonjudicial foreclosures.” Facklam v. HSBC Bank USA for Deutsche ALT-A Sec. Mortg. Loan Tr., 401 P.3d 1068, 1071 (Nev. 2017). “Nonjudicial foreclosure is neither a civil nor a criminal judicial proceeding. It is not commenced by filing a complaint with the court.” Id. The foreclosure at issue here is a nonjudicial foreclosure. It was not commenced by filing a complaint, but rather by recording a Notice of Default and Election to Sell Under Deed of Trust. (ECF No. 40-4.) NRS 11.190 is inapplicable here.Read the full opinion on CourtListener →
Statute of limitations—Accrual of tort claims
Section 11.190(4)(e) supplies a two-year limitations period for tort claims, running from when the cause of action accrues.
Coombes v. Washoe County School District · filed 2024-03-27(4)(e)
The Court applies the generally applicable statute of limitations, NRS11.190(4)(e). The parties disagree about when 11.190(4)(e)’s two-year limitations period began. Under Nevada law, for torts like NIED, IIED, and NTS, the limitations period begins “the day the cause of action accrued.” Clark v. Robison, 944 P.2d 788, 789 (Nev. 1997). “A cause of action ‘accrues’ when a suit may be maintained thereon.” Id. ... Taking Mr. Coombes’s allegations as true for purposes of this motion, his claims for IIED, NIED, and NTS (Claims 3, 4, and 5) accrued when his request for accommodations was denied and he was reinstated without pay sometime after August 15, 2020. ... He filed his complaint on August 16, 2022. (ECF No. 1.) Mr. Coombes’s Claims 3, 4, and 5 are therefore timely as to those alleged harms.Read the full opinion on CourtListener →
Statute of limitations—false imprisonment
Section 11.190(4)(e) imposes a two-year statute of limitations on false-imprisonment claims.
Harris v. County of Clark · filed 2024-05-22(4)(e)
The statute of limitations for bringing a 42 U.S.C. § 1983 action is determined by state law. Under Nevada law, the statute of limitations for bringing a false imprisonment claim is two years. Nev. Rev. Stat. § 11.190(4)(e).Read the full opinion on CourtListener →
Discovery-rule tolling
Section 11.190(4)(e) sets a two-year limitations period for personal-injury and wrongful-death claims, which may be tolled by the discovery rule when the plaintiff could not reasonably have discovered the claim earlier despite diligent investigation or when the defendant concealed the relevant facts.
ADKINS v. UNION PAC. R.R. CO. · filed 2024-08-15(4)(e)
We therefore conclude that the discovery rule may toll NRS 11.190(4)(e)'s two-year limitations period where the plaintiff is not aware of a cause of action because of the defendant's concealment of the facts constituting the plaintiff s claims, see Siragusa, 114 Nev. at 1393-94, 971 P.2d at 807, or "where the occurrence and the manifestation of damage are not contemporaneous," Oak Grove, 99 Nev. at 622, 668 P.2d at 1078, such that, despite diligent investigation, the plaintiff did not discover and could not reasonably be expected to have discovered facts supporting a cause of action earlier, Petersen, 106 Nev. at 274, 792 P.2d at 20.Read the full opinion on CourtListener →
Limitations period for enforcement of judgments
Section 11.190(1)(a) imposes a six-year limitation period on an action upon a judgment or decree of a United States court, including execution of a civil federal judgment when no applicable federal statute governs.
Federal Trade Commission v. Ivy Capital, Inc. · filed 2024-08-20(1)(a)
In Nevada, there is a six-year limitation period for any “action upon a judgment or decree of any court of the United States.” NRS 11.190(1)(a). In the FTC’s action against Rodgers, there is no applicable federal statute governing the execution of the judgment. Accordingly, Nevada’s six-year limitation applies.Read the full opinion on CourtListener →
Written contracts and unjust enrichment
Section 11.190(1)(b) provides a six-year limitations period for written-contract actions, while § 11.190(2)(c) provides a four-year limitations period for unjust-enrichment claims.
Sunrise Hospital and Medical Center, LLC v. Blue Shield of California, Inc. · filed 2024-08-23(1)(b), (2)(c)
State statutes of limitations for claims based on written contracts provide “the applicable statute of limitations for an ERISA cause of action based on a claim for benefits under a written contractual policy.” Id. at 648. Nevada has a six-year statute of limitations for “[a]n action upon a contract . . . founded upon an instrument in writing.” Nev. Rev. Stat. § 11.190(1)(b). ... Moreover, “[t]he statute of limitation for an unjust enrichment claim is four years.” In re Amerco Derivative Litig., 252 P.3d 681, 703 (Nev. 2011) (en banc) (citing Nev. Rev. Stat. § 11.190(2)(c)).Read the full opinion on CourtListener →
Statute of limitations — deceptive trade practices
Section 11.190(2)(d) gives NDTPA claims a four-year limitations period running from when the aggrieved party discovers, or should through due diligence discover, the facts constituting the deceptive trade practice.
Watkins v. Rapid Financial Solutions, Inc. · filed 2024-08-26(2)(d)
The NDTPA has a four-year limitations period which begins to accrue “when the aggrieved party discovers, or by the exercise of due diligence should have discovered, the facts constituting the deceptive trade practice.” NRS § 11.190(2)(d).Read the full opinion on CourtListener →
Section 11.190(2)(d) imposes a four-year limitations period for deceptive-trade-practice claims, accruing when the aggrieved party discovers or should have discovered the facts constituting the deceptive trade practice.
Dae Sung Hi Tech Co., LTD v. D&B Sales, Inc. · filed 2025-02-18(2)(d)
The statute of limitations for claims under the NDTPA is four years from the accrual of the action, which occurs upon discovery of the facts constituting the deceptive trade practice. NRS 11.190(2)(d).Read the full opinion on CourtListener →
Section 11.190(2)(d) provides a four-year limitations period for Nevada deceptive trade practices claims.
WILKINS v. GENZYME CORPORATION · filed 2022-09-14(2)(d)
Four years for the Nevada Deceptive Trade Practices Act.Read the full opinion on CourtListener →
Statute of limitations for unjust-enrichment claims
Section 11.190(2)(c) provides a four-year statute of limitations for unjust-enrichment claims.
Van Damme v. U.S. Bank N.A., as Trustee · filed 2024-09-19(2)(c)
In Nevada, the statute of limitations for an unjust-enrichment claim is four years.Read the full opinion on CourtListener →
Section 11.190(2)(c) imposes a four-year limitations period on unjust-enrichment claims.
Van Damme v. U.S. Bank N.A., as Trustee · filed 2024-11-26(2)(c)
It’s clear from the face of Van Damme’s complaint that his unjust-enrichment claim is time-barred. In Nevada, the statute of limitations for an unjust-enrichment claim is four years. At the latest, Van Damme knew about the facts giving rise to this claim in 2015 when U.S. Bank was listed as trustee on a notice of default and election to sell recorded against the property. Indeed, he alleged in his 2015 complaint various deficiencies in the assignment of his loan to U.S. Bank, relying on largely the same arguments he raises here. But he did not bring an unjust-enrichment claim then, and his attempt to do so now is at least five years too late. So I dismiss this claim as time barred and I do not reach U.S. Bank’s alternative arguments for its dismissal.Read the full opinion on CourtListener →
Six-year limitation for actions on written contracts
Section 11.190(1)(b) imposes a six-year limitations period on actions based on a written contract, obligation, or liability.
Van Norden v. Blackwater Legal Group · filed 2024-12-10(1)(b)
A suit to enforce the contract for Van Norden’s payday loan would have been time-barred by NRS 11.190(1)(b)’s six-year statute-of-limitations as the debt was well over six years old at the time of Blackwater’s collection attempt.Read the full opinion on CourtListener →
Six-year limitations period for written obligations
The six-year limitations period applies to an obligation or liability founded on an instrument in writing; a writing need only fairly import an obligation to pay, and a signed employment-verification letter may qualify.
Taber v. Exemplar Holdings, LLC · filed 2025-03-11(1)(b)
The Court finds that Defendant has not met its initial burden to show that Plaintiff has not presented evidence of an “instrument in writing” under NRS § 11.190(1)(b). ... Under our statute, as interpreted by authorities that have concerned themselves with the same language, all that is required is that there be a writing which fairly imports the obligation to pay. This is a fair construction of the statute, consistent with its language and with the legislative purpose to allow a longer time to commence an action for which there is solid written proof. In the absence of signed documentation, our ruling may be different, and such situation will be considered when it arises. ... Here, a reasonable trier of fact could find that the employment-verification letter constitutes an instrument in writing under NRS § 11.190(1)(b). ... Based on these details—salary, title, work periods, expenses, signature—a reasonable trier of fact could conclude that the letter “fairly imports” an obligation for Defendant to pay Plaintiff for his work on the screw project.Read the full opinion on CourtListener →
Breach of contract—six-year limitation period
Section 11.190(1)(b) requires a breach-of-contract action to be filed within six years after it accrues.
Karalis v. Carn · filed 2025-07-30(1)(b)
NRS § 11.190(1)(b) requires a breach of contract action to be brought within six years of its accrual. A cause of action for breach of contract accrues on the date of “the last transaction or the last item charged or last credit given.” NRS § 11.200(1). This statutory definition of accrual comports with the longstanding rule “applicable in all cases” that the limitation period “begins to run when the debt is due, and an action can be instituted upon it.” Davidson v. Davidson, 382 P.3d 880, 885 (Nev. 2016) (en banc) (simplified).Read the full opinion on CourtListener →
Tort claims—Two-year limitation period
Section 11.190(4)(e) imposes a two-year limitation period on tort claims, but an amended claim arising from the same conduct as a timely original pleading relates back and is not time-barred.
STATE, COMM'R OF INS. v. CHUR C/W 85728 · filed 2025-12-23(4)(e)
The Directors further argue that the amended complaint would be futile as barred by the applicable statute of limitations in NRS 11.190(4)(e). We again disagree. NRS 11.190(4)(e) provides a two-year limitation period for tort claims. Thus, if newly asserted, the Commissioner's breach of fiduciary duty claim would be time-barred. But an amended pleading relates back to the date of the original pleading and thus is not time-barred if the original pleading is timely when "the amendment asserts a claim or defense that arose out of the conduct, transaction, or occurrence set out—or attempted to be set out—in the original pleading." NRCP 15(c)(1). Here, the amendment asserts a claim that arose out of the Directors' conduct related to L&C and its insolvency—just as the claims raised in the Commissioner's original complaint—and thus the claim arises from the conduct challenged in the original, timely complaint. Accordingly, the amendment relates back and was not barred by the statute of limitations. We conclude that the Directors have failed to show futility in this regard as well.Read the full opinion on CourtListener →
Statute of limitations—Estoppel and misrepresentation
Section 11.190(2)(c) imposes a four-year limitation period for estoppel claims, while § 11.190(3)(d) imposes a three-year limitation period for misrepresentation claims.
Bruton v. Specialized Loan Servicing, LLC · filed 2026-03-12(2)(c), (3)(d)
As the district court also correctly held, this theory is time-barred. Any representations concerning extinguishment at the time of loan modification occurred in 2013 and any misrepresentation by silence ended in 2017, well over four years before this action was filed in 2023. Nev. Rev. Stat. § 11.190(2)(c) (four-year statute of limitation for estoppel); Nev. Rev. Stat. § 11.190(3)(d) (three-year statute of limitation for misrepresentation).Read the full opinion on CourtListener →
Notes 301–348 of 348, oldest cases first.
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