Nev. Rev. Stat. § 17.130
Computation of judgment amount; interest on judgments: the cases that interpreted this section
74 citing cases reviewed of 100 in the citation index: 56 interpreted the section (annotated below), 18 cited it only in passing. Cases filed after 2025-12-29 may not have been reviewed yet.
Have a situation under Nev. Rev. Stat. § 17.130?
These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.
Later changes in law
Changes after the earliest notes below. A note stating a rule one of these changed is marked "Law changed since".
- 1979-07-01 Chapter 448 changed § 17.130(2) from seven percent interest beginning at judgment to eight percent interest beginning with service of the summons and complaint, except that future damages accrue interest only after judgment; the change applies to actions filed on or after this date. Source
- 1981-07-01 Chapter 739 raised the fixed judgment interest rate in § 17.130(2) from eight to twelve percent for causes of action arising on or after this date. Source
- 1987-07-01 Chapter 413 replaced the fixed twelve percent rate with the Nevada prime rate plus two percentage points and required adjustments each January and July after judgment for causes of action arising on or after this date. Source
Prejudgment interest
Section 17.130(2) bars prejudgment interest on future damages and requires use of the effective statutory interest rate rather than a rate chosen by the district court.
Jacobson v. Manfredi by Manfredi · filed 1984-04-03(2)
NRS 17.130(2) clearly prohibits prejudgment interest on future damages. ... NRS 17.130(2) does not, contrary to respondents’ interpretation, endow the district court with power to choose an interest rate. We hold that the district court is bound by the effective statutory interest rate.Read the full opinion on CourtListener →
Section 17.130(2) permits prejudgment interest when the damages award does not commingle past and future damages.
Ramadanis v. Stupak · filed 1988-03-31(2)
By separate motions, Ramadanis and Marathon then moved for prejudgment interest pursuant to NRS 17.130(2) and attorney’s fees pursuant to NRS 18.010. ... Where an award fails to distinguish past damages from future damages and such past damages are combined with future damages, there can be no award of prejudgment interest. ... There was no commingling of past and future damages apparent in the jury’s verdict; therefore, the award of prejudgment interest on the damages for which Stupak is liable is proper.Read the full opinion on CourtListener →
Section 17.130(2) makes prejudgment interest mandatory rather than discretionary.
McCalla v. Royal MacCabees Life Insurance Company · filed 2004-06-03(2)
The Nevada prejudgment interest statute is undoubtedly mandatory.Read the full opinion on CourtListener →
Section 17.130(2) makes prejudgment interest run from service of the summons and complaint, at the single rate in effect when judgment is entered.
Alutiiq International Solutions, LLC v. OIC Marianas Insurance · filed 2016-01-14(2)
The prejudgment-interest award against these defendants, if any, is authorized instead by NRS 17.130, which provides that the judgment draws interest from the time of service of the summons and complaint. ... The prejudgment interest rate under NRS 17.130 is the one in effect at the time of the entry of the judgment, which is 5.50%.Read the full opinion on CourtListener →
The 1979 amendment authorizing prejudgment interest applies only to actions and proceedings filed on or after July 1, 1979.
Hernandez v. City of Salt Lake · filed 1984-08-24
At the time the legislature amended the statute in 1979 to allow prejudgment interest, it expressly provided that the provisions of the act would apply “to all actions and proceedings filed on or after July 1, 1979.” 1979 Nev. Stats, ch. 448 § 6, at 831. The complaint in this case was filed January 28, 1977. Accordingly, prejudgment interest was not authorized by the statute in this case.Read the full opinion on CourtListener →
Section 17.130 allows prejudgment interest on judgments for debt, damages, or costs, runs on past damages from service of the summons and complaint, excludes future damages, and uses the single rate in effect on the judgment date.
Albios v. Horizon Communities, Inc. · filed 2006-04-27(1), (2)
Under NRS 17.130(2), “the judgment draws interest from the time of service of the summons and complaint until satisfied, except for any amount representing future damages.” ... Under the plain language of NRS 17.130(1), prejudgment interest is recoverable on judgments awarding costs. ... The plain language of NRS 17.130(1) states that prejudgment interest is awarded on judgments “for any debt, damages or costs.” ... Accordingly, we hold that when attorney fees are awarded as an element of damages, the prevailing party is entitled to recover prejudgment interest on the attorney fees. As the attorney fees are awarded as an element of past damages, attorney fees draw interest from the time of service of the summons and complaint, as specified in NRS 17.130(2). ... Under NRS 17.130(2), prejudgment interest is calculated at “the single rate in effect on the date of judgment.”Read the full opinion on CourtListener →
Section 17.130 requires interest on damages incurred after service of the complaint but before judgment to accrue from when the damages actually occur, rather than from the complaint date or judgment date.
Las Vegas-Tonopah-Reno Stage Lines, Inc. v. Gray Line Tours · filed 1990-05-16
Accordingly, we conclude that interest should begin to accrue from the time damages actually occur if they are sustained after the complaint is served but before judgment, rather than from the date of serving the complaint or from the date of judgment.Read the full opinion on CourtListener →
Section 17.130 sets prejudgment interest at 2% plus the prime rate at Nevada's largest bank, assessed as simple annual interest from service of the summons.
Oracle USA, Inc. v. Rimini Street, Inc. · filed 2016-09-21
Nevada law establishes a prejudgment interest rate of 2% plus “the prime rate at the largest bank in Nevada ascertained by the Commissioner of Financial Institutions on January 1 or July 1, as the case may be, immediately preceding the date of judgment.” NRS 17.130.Read the full opinion on CourtListener →
Section 17.130(2) provides that prejudgment interest runs from the time of service of the summons and complaint, at the statutory rate.
Halo Electronics, Inc. v. Bel Fuse Inc. · filed 2023-03-07(2)
I will award Halo prejudgment interest at the rate set forth in Nev. Rev. Stat. § 17.130, compounded annually, through September 6, 2017. Prejudgment interest runs from “the time of service of the summons and complaint . . . .” Nev. Rev. Stat. § 17.130(2).Read the full opinion on CourtListener →
Section 17.130(2) authorizes an award of prejudgment interest on a judgment.
Wright v. Scoma · filed 2023-04-25(2)
Wright is entitled to prejudgment interest on his judgment. Nev. Rev. Stat. § 17.130(2). Wright may file a supplemental brief showing the calculation of that amount by May 5, 2023.Read the full opinion on CourtListener →
Section 17.130 provides that prejudgment interest accrues from the time the summons and complaint are served.
Obelisk Capital Management Limited v. Precise Global Trade, LLC · filed 2024-01-22
Since the rules are silent on when that interest begins to accrue, the Court will follow Nevada law wherein the interest accrues -- “from the time of service of the summons and complaint.” NRS § 17.130. The summons was returned executed on June 14, 2021 and therefore prejudgment interest will accrue from this date.Read the full opinion on CourtListener →
Section 17.130(2) sets prejudgment interest at the prime interest rate at the time of judgment plus two percent for the specified claims.
Great West Capital, LLC v. Payne · filed 2025-08-27(2)
As for Eastgate’s breach of contract claim and Defendants’ breach of contract and unjust enrichment claims, see Crockett & Myers, Ltd. v. Napier, Fitzgerald & Kirby, LLP, 567 F. App’x 527, 528 (9th Cir. 2014) (assuming without deciding that Nevada law allows recovery of prejudgment interest on an unjust enrichment claim), the interest rate on each of these claims is the prime interest rate at the time of judgment, plus two percent, Nev. Rev. Stat. §§ 17.130(2), 99.040(1). The prime interest rate in Nevada on January 1, 2025, was 8.00%.Read the full opinion on CourtListener →
Section 17.130 sets the applicable prejudgment-interest rate at 10% for the court's calculation.
Pacira Pharmaceuticals, Inc. v. Research Development Foundation · filed 2025-08-28
The court finds that prejudgment interest shall be calculated pursuant to NRS 17.130. ... Under § 17.130, the applicable interest rate is 10%. See “Legal Interest Rate,” https://www.washoecourts.com/TopRequests/InterestRates.Read the full opinion on CourtListener →
Section 17.130 sets the interest rate at the applicable Nevada prime rate plus two percentage points when no other rate applies.
Wood v. Nautilus Insurance Company · filed 2023-12-18
Under NRS § 17.130, two percent is added to the prime rate, so the appropriate pre-judgment interest rate here is 10.25% per year.Read the full opinion on CourtListener →
Section 17.130(2) provides prejudgment interest from service of the summons and complaint until entry of judgment at the prime rate at judgment plus two percent.
Decollibus v. Rubus Management, LLC · filed 2025-01-14(2)
Under NRS 17.130(2), a prevailing party is entitled to prejudgment interest from the time of service of the summons and complaint until the entry of judgment, at ... the prime interest rate at the time of judgment, plus two percent.Read the full opinion on CourtListener →
Section 17.130(2) permits prejudgment interest to accrue through the date default judgment is entered.
Gini Services, LLC v. Perle Technologies, Inc. · filed 2025-06-06(2)
IT IS FURTHER ORDERED that plaintiffs are awarded $1,477,305.66 in damages and $350,607.13 in pre-judgment interest through December 11, 2024, plus the per diem amount until ... the date default judgment is entered pursuant to NRS 17.130(2).Read the full opinion on CourtListener →
Section 17.130(2) requires prejudgment interest on a contract judgment when no other interest rate is provided.
Day v. West Coast Holdings, Inc. · filed 1985-05-21(2)
There is no evidence supporting the district court’s denial of prejudgment interest. R.J. was awarded judgment under the contract between the parties. The district court erred in failing to award prejudgment interest.Read the full opinion on CourtListener →
Prejudgment interest on punitive damages
Section 17.130(2) does not permit prejudgment interest on punitive damages because their amount cannot be ascertained until the judgment is rendered.
Ramada Inns, Inc. v. Sharp · filed 1985-12-31(2)
Because the amount of punitive damages to be awarded is not known until the judgment is rendered, we hold that prejudgment interest may not be granted by a trial court'.on' punitive damage awards.Read the full opinion on CourtListener →
Section 17.130(2) permits prejudgment interest on an entire verdict when the record does not show that the verdict includes future damages, but excludes any amount representing future damages from interest.
Bongiovi v. Sullivan · filed 2006-07-13(2)
A ‘ ‘judgment draws interest from the time of service of the summons and complaint until satisfied, except for any amount representing future damages.” ... But when there is nothing in the record to suggest that future damages were included in the award, prejudgment interest on the verdict is allowed. ... Thus, even when a jury instruction expressly allows the jury to consider future damages, if the record does not indicate any reference to future damages in evidence, prejudgment interest awarded on the entire verdict is proper.Read the full opinion on CourtListener →
Subsection (2) permits prejudgment interest on the entire personal-injury award when the award compensates for damages incurred before the verdict, not merely past medical bills.
State v. Eaton · filed 1985-12-10(2)
The personal injury award was based on jury instructions compensating Chrystal for her medical expenses, pain and suffering incurred to the date of the jury verdict. These constitute past damages. Therefore, the entire amount is subject to prejudgment interest.Read the full opinion on CourtListener →
Section 17.130(2) bars prejudgment interest on a judgment that includes future damages.
Hazelwood v. Harrah's · filed 1993-11-03(2)
NRS 17.130(2) disallows prejudgment interest for a judgment representing future damages.Read the full opinion on CourtListener →
Section 17.130(2) permits prejudgment interest on construction-defect damages that accrued when the homes were built, including unexpended repair costs, even if the repairs will be made later.
Shuette v. Beazer Homes Holdings Corp. · filed 2005-12-15(2)
Here, we conclude that prejudgment interest was properly awarded on the entire verdict, as the award represented only past damages, because the damages occurred when the homes were built, regardless of when the homeowners actually made or will make necessary repairs.Read the full opinion on CourtListener →
Section 17.130(2) bars prejudgment interest on any portion of a judgment representing future damages.
Valley Health Sys., LLC v. Murray · filed 2024-03-14(2)
Nevada law is clear: prejudgment interest cannot be awarded on future damages. See NRS 17.130(2) (stating that "the judgment draws interest from the time of service of the summons and complaint until satisfied, except for any amount representing future damages").Read the full opinion on CourtListener →
Section 17.130 allows prejudgment interest on costs when a party can substantiate when those costs were incurred.
Bobby Berosini, Ltd. v. People for the Ethical Treatment of Animals · filed 1998-12-30(1)
Although Berosini contends that neither Gibellini nor NRS 17.130 entitle a party to prejudgment interest as a matter of right, in Gibellini we indicated that prejudgment interest will be disallowed only in those situations where a party is unable to substantiate when a particular cost was incurred. Accordingly, the district court abused its discretion in denying PETA prejudgment interest on costs.Read the full opinion on CourtListener →
Section 17.130 allows post-judgment interest on punitive damages because they are part of the prevailing plaintiff’s judgment.
Albert H. Wohlers & Co. v. Bartgis · filed 1999-02-19(2)
In Powers v. USAA, 114 Nev. 690, 962 P.2d 596 (1998), we held that NRS 17.130 allowed for post-judgment interest on punitive damages on the reasoning that such damages comprise part of a prevailing plaintiff’s judgment as defined by NRS 17.130. ... Accordingly, pursuant to our decision in Powers, Bartgis is entitled to post-judgment interest on her punitive damage award.Read the full opinion on CourtListener →
Section 17.130 allows prejudgment interest on past damages only when their amount can be established; future damages draw interest only from entry of judgment.
Stickler v. Quilici · filed 1982-12-29(2)
Since it is impossible to determine what portion of the total verdict was for past damages, the amount of the award for which prejudgment interest can be properly awarded is not ascertainable. It was therefore error for the trial court to award prejudgment interest on the entire amount of the jury verdict.Read the full opinion on CourtListener →
Section 17.130 requires prejudgment interest to account for the distinction between past and future damages.
Wilkes v. Anderson · filed 1984-07-03
The record reveals, however, that the judgment on the verdict included prejudgment interest on the entire verdict without distinguishing between past and future damages, in apparent contravention of NRS 17.130.Read the full opinion on CourtListener →
Section 17.130(2) permits prejudgment interest on mental distress damages when the record does not indicate that the award includes future damages.
Farmers Home Mutual Insurance v. Fiscus · filed 1986-09-04(2)
Prejudgment interest in this case constitutes compensation for use by Farmers of money to which the Fiscuses were entitled from the time of the cause of action until the time of judgment. There was no testimony regarding future mental distress nor lack of clarity in the record to indicate the trial court improperly awarded prejudgment interest for future mental distress damage. Farmers’ argument on this point is without merit.Read the full opinion on CourtListener →
Section 17.130 does not authorize a court to add prejudgment interest to an arbitration award when confirming it.
Mausbach v. Lemke · filed 1994-01-20(2)
For the above reasons, we conclude that, absent statutory or contractual authority, a district court in a confirmation proceeding may not add prejudgment interest to the arbitration award. Therefore, the district court properly declined to award prejudgment interest when it confirmed the arbitrator’s award in this case.Read the full opinion on CourtListener →
Section 17.130(2) allows post-judgment interest on punitive damages from the date judgment is entered.
Powers v. United Services Automobile Ass'n · filed 1998-07-16(2)
Finally, we conclude that Powers is entitled to post-judgment interest on his punitive damages award as of the date the district court entered the judgment.Read the full opinion on CourtListener →
Judgment interest when no other rate is provided
Section 17.130(2) supplies the judgment-interest rate only when no other rate is provided by contract or law; it does not govern a contract-rescission suit to which § 99.040 applies.
Wilson v. Pacific Maxon, Inc. · filed 1986-02-26(2)
Instead, Wilson argues, the interest award in this case should be governed by NRS 17.130(2), which provides that interest must be allowed on judgments in all cases where no other rate of interest is provided for by contract or by law. ... We disagree. A suit for rescission of a contract is a suit arising out of a contract to which NRS 99.040 applies. ... Therefore, NRS 99.040 governs the award of interest in this case.Read the full opinion on CourtListener →
Subsection (2) is the general interest-calculation provision when no contractual or statutory rate applies, but it does not govern a contractual amount with an ascertainable due date when NRS 99.040(1) applies.
State Drywall, Inc. v. Rhodes Design & Development · filed 2006-02-09(2)
Because this case involves a contractual amount for which an ascertainable due date exists, NRS 99.040, not NRS 17.130(2), applies.Read the full opinion on CourtListener →
Section 17.130(2) does not impose judgment interest when the parties expressly agreed that no interest would be charged.
Jacobson v. Best Brands, Inc. · filed 1981-08-31(2)
Accordingly, the provisions of NRS 17.130(2) ... and NRS 99.040 ... do not apply. Since the parties agreed that no interest be charged under the guaranty instrument, a judgment rendered on such contract must conform thereto.Read the full opinion on CourtListener →
Interest on judgments
The former version of § 17.130(2) required seven-percent interest on the entire judgment from entry until satisfaction, without distinguishing between prejudgment and post-judgment interest or past and future damages.
BHY Trucking, Inc. v. Hicks · filed 1986-06-26(2)
This former version of the statute does not distinguish between pre-judgment interest and post-judgment interest; nor does it distinguish between past and future damages as the present version does. The statute merely provides for interest at seven percent per annum starting with the date of entry of the judgment and ending upon payment. Therefore, we hold that the lower court’s assessment of interest was incorrect and must be vacated and replaced with a rate of seven percent per annum assessed on the entire judgment ($350,000.00) beginning with the date of entry of the judgment until paid.Read the full opinion on CourtListener →
Section 17.130(2) supports awarding post-judgment interest on a contractual debt when the parties have no agreement governing interest.
Humana, Inc. v. Nguyen · filed 1986-12-04(2)
Nguyen’s indebtedness to the hospital is contractual in nature, and .the record discloses no cognizable agreement with respect to interest. Therefore, Sunrise was entitled to both prejudgment and post-judgment interest. NRS 99.040; NRS 17.130(2).Read the full opinion on CourtListener →
Section 17.130 requires application of the statutory interest rate rather than unfettered judicial discretion, and its reference to judgments for debt, damages, or costs makes prejudgment interest recoverable on costs.
Gibellini v. Klindt · filed 1994-11-30(1), (2)
Moreover, respondents’ reading of the statute would leave the district court judge with unfettered discretion to set interest rates on judgments, which was most likely not the intent of the legislature, and which is at variance with the common law. ... Accordingly, we conclude that the district court erred in awarding IOV2 percent interest on the judgment rather than the statutory rate, and reverse and remand this portion of the judgment with instructions to amend the award by applying the statutory rate. ... We reject this argument based on a plain reading of NRS 17.130, which provides for the recovery of interest on the “judgment.” NRS 17.130(1) refers to “judgments ... for any debt, damages or costs.” Thus, we conclude that the term “judgment” encompasses both damages and costs, so that prejudgment interest is recoverable on costs.Read the full opinion on CourtListener →
Section 17.130(2) sets a default judgment-interest rate that yields simple interest, not compound interest, unless a contract or statute provides otherwise.
Torres v. Goodyear Tire & Rubber Co. · filed 2014-01-30(2)
Interest is simple unless otherwise stated in a contract or statute. Because NRS 17.130(2) does not provide for compound interest, interest awarded under this statute is simple.Read the full opinion on CourtListener →
Section 17.130(2) provides interest on a judgment when no rate is set by contract, law, or the judgment; here it applied because PERS’s obligation to pay survivor benefits was statutory, not contractual.
PUB. EMPLOYEES' RETIREMENT SYS. OF NEVADA VS. GITTER C/W 69208/69961 · filed 2017-04-27(2)
NRS 17.130(2) provides for interest on any judgment "[wIlien no rate of interest is provided by contract or otherwise by law, or specified in the judgment." ... The district court erred in concluding that Gitter's survivor benefits constituted money due in a case upon a contract. Pensions are part of an employment contract, see Pub. Emps.' Ret. Bd. v. Washoe Cty., 96 Nev. 718, 722, 615 P.2d 972, 974 (1980), but Gitter has not produced a contract to which she is the intended beneficiary—PERS's obligation to pay survivor benefits is statutory, not contractual, and a designation form identifying a member's intended beneficiaries is not a contract. Thus, we reverse the district court's award of interest under NRS 99.040(1)(a) and remand with instructions for the district court to award interest under NRS 17.130.Read the full opinion on CourtListener →
Section 17.130 supplies the terms for awarding pre- and post-judgment interest on the plaintiff’s damages.
Xing v. USA Good Travel and Tour Inc. · filed 2024-10-23
Plaintiff is also entitled to pre- and post-judgment interest per the terms of NRS § 17.130. Plaintiff’s attorney must accordingly include with their written attorneys’ fees submission updated damages totals taking the amounts included above and adding the appropriate pre- and post-judgment interest amounts to them.Read the full opinion on CourtListener →
Section 17.130(2) provides that a judgment accrues interest from service of the summons and complaint until the judgment is satisfied.
Ameritina Dental Craig LLC dba Nevada Dentistry and Braces v. Ray America, Inc., et al. · filed 2025-09-30(2)
Furthermore, under NRS 17.130(2), a judgment accrues interest from the date of the service of the summons and complaint until the date judgment is satisfied.Read the full opinion on CourtListener →
Section 17.130(2) sets judgment interest at the applicable Nevada prime rate plus two percentage points when no other rate applies.
Spencer v. Stafford · filed 2021-02-26(2)
The 3.25% prime rate established by the Nevada Financial Institutions plus 2% is 5.25%. Applying that figure to a principal amount of ... $250,000 yields an annual interest figure of about $13,125.40 at an approximate daily accrual of ... $35.96 (rounded up).Read the full opinion on CourtListener →
Law changed since Chapter 448 (effective July 1, 1979) made interest on covered past damages run from service of the summons and complaint for actions filed on or after that date; future damages still draw interest only after judgment.
Section 17.130(2) makes interest on an industrial insurance award run from entry of the trial court’s judgment.
Nevada Industrial Commission v. Strange · filed 1968-02-28(2)
We find no reason why the rule announced in NRS 17.130(2) ... is not applicable in the instant case and ... that interest should run only from the date of entry of the trial court’s award.Read the full opinion on CourtListener →
Section 17.130 distinguishes between past and future damages and applies when no interest rate is provided by contract, other law, or the judgment.
Uniroyal Goodrich Tire Co. v. Mercer · filed 1995-03-02
NRS 17.130, on the other hand, which does distinguish between past and future damages, only comes into play “[w]hen no rate of interest is provided by contract or otherwise by law, or specified in the judgment.”Read the full opinion on CourtListener →
Section 17.130(2) prohibits calculating post-judgment interest in a way that continuously compounds interest over time.
Westgate Planet Hollywood Las Vegas, Llc Vs. Tutor-Saliba Corp. · filed 2019-09-27(2)
We hold that the district court erred in concluding $1,974,838 of prejudgment interest was subject to 8 percent in post-judgment interest. Any other conclusion would continuously compound interest over time as prohibited by NRS 17.130(2) ... and Torres.Read the full opinion on CourtListener →
Interest on workers’ compensation awards
Section 17.130 does not apply to an award of workers’ compensation benefits.
Weaver v. State Industrial Insurance System · filed 1988-06-28
By their own terms, NRS 99.040, NRS 17.130 and NRAP 37 do not purport to apply to an award of workers’ compensation.Read the full opinion on CourtListener →
Post-judgment interest on attorney fees
Section 17.130(1) authorizes post-judgment interest on attorney-fee awards because those awards are costs included in a judgment.
Waddell v. L.V.R v. Inc. · filed 2006-01-19(1)
NRS 17.130(1) provides for interest to be granted on “all judgments and decrees, rendered by any court of justice, for any debt, damages or costs.” We have never directly addressed the issue of whether the recipient of an attorney fees award is entitled to post-judgment interest on that award. ... For the same reason, we conclude that the prevailing party may recover post-judgment interest on an attorney fees award.Read the full opinion on CourtListener →
Section 17.130 sets post-award, pre-judgment interest at the prime rate at Nevada's largest bank, ascertained by the Commissioner of Financial Institutions, plus 2 percent, with rate adjustments each January 1 and July 1 until payment.
Lagstein v. Certain Underwriters at Lloyd's of London · filed 2013-08-05
Post-award, pre-judgment interest on the non-contract damages should be calculated “at a rate equal to the prime rate at the largest bank in Nevada as ascertained by the Commissioner of Financial Institutions” on July 1, 2006, “plus 2 percent.” Nev. Rev. Stat. § 17.130. “The rate must be adjusted accordingly on each January 1 and July 1 thereafter” until the date Lloyd’s satisfied the judgment. Id.Read the full opinion on CourtListener →
Section 17.130(2) provides for post-judgment interest at the statutory rate on the judgment.
8 Mine, LLC v. The Eljen Group, LLC · filed 2020-10-26(2)
The Eljen Group/Jennings are also entitled to post-judgment interest at the statutory rate under NRS 17.130(2).Read the full opinion on CourtListener →
Date of judgment triggering prejudgment-interest rate
Section 17.130(2) sets the prejudgment-interest rate using the rate immediately preceding the date of judgment, and when an appellate modification changes the judgment amount, the original judgment date controls.
Schiff v. Winchell · filed 2010-08-12(2)
NRS 17.130(2) provides, in relevant part, that the interest rate to be applied to any prejudgment interest is the rate that is established “immediately preceding the date of judgment.” ... Under NRS 17.130(2)’s plain language, we have not previously been called upon to determine what judgment date applies when this court affirms in part, reverses in part, and remands the matter to the district court with instructions to offset a plaintiff’s award. ... Since this court effectively affirmed the original judgment in the prior appeal in this case, we conclude that the original date of the district court judgment should set the prejudgment interest rate as set forth in NRS 17.130(2).Read the full opinion on CourtListener →
Time from which judgment interest accrues
Section 17.130(2) makes a judgment draw interest from service of the summons and complaint until it is satisfied, so prejudgment interest runs from service of the operative complaint.
Sobel v. Hertz Corp. · filed 2013-03-21(2)
NRS § 17.130(2) provides that “the judgment draws interest from the time of service of the summons and complaint until satisfied.” ... Therefore, Plaintiffs are entitled to prejudgment interest at the statutory rate dating from the service of the First Amended Complaint (which defines the relevant class).Read the full opinion on CourtListener →
Prejudgment interest in eminent domain actions
Section 17.130(2) is a general prejudgment-interest statute and is not the appropriate provision for calculating interest on precondemnation damages when the eminent-domain-specific NRS 37.175 applies.
City of N. Las Vegas v. 5th & Centennial · filed 2014-08-07(2)
Further, we concluded that NRS 37.175(4) is more appropriate than NRS 17.130(2), the general prejudgment interest statute, for calculating precondemnation damages because NRS 37.175 is specific to eminent domain cases.Read the full opinion on CourtListener →
Prejudgment interest—rate and accrual period
Section 17.130(2) requires prejudgment interest to be calculated at the single statutory rate in effect on the date of judgment, accruing from service of the summons and complaint until the judgment is satisfied.
Lee v. Ball · filed 2005-07-28(2)
The district court calculated the rate of prejudgment interest using periodic biannual legal rates of interest in effect between May 27, 1999, and March 24, 2003. This was error. ... Under the plain language of NRS 17.130(2), the district court should have calculated prejudgment interest at the single rate in effect on the date of judgment. ... NRS 17.130(2) explicitly provides that “the judgment draws interest from the time of service of the summons and complaint until satisfied.”Read the full opinion on CourtListener →
Section 17.130 sets prejudgment interest at the prime rate plus two percent, fixed at the rate in effect on the judgment date, and provides that a judgment draws interest from service of the summons and complaint.
Nautilus Insurance Company v. Access Medical, LLC · filed 2023-03-28(2)
The rate of interest is “the prime rate . . . plus 2 percent.” Nev. Rev. Stat. § 17.130. That rate is fixed and “calculated at the single rate in effect on the date of judgment.” Kerala Properties, 137 P.3d at 1150. ... Nev. Rev. Stat. § 17.130(2) (“The judgment draws interest from the time of service of the summons and complaint); ... I find that Nevada Revised Statute (NRS) 17.130 rather than 99.040 applies because this case does not “involve[] a contractual amount for which an ascertainable due date exists.”Read the full opinion on CourtListener →
Law changed since Chapter 413 (effective July 1, 1987) replaced the fixed rate for later-arising causes with the Nevada prime rate plus two percentage points, adjusted each January and July after judgment.
The interest rate in effect when a cause of action arose applies until the judgment is satisfied; the 1981 increase from eight to twelve percent applies to causes of action arising on or after July 1, 1981.
Arnold v. Mt. Wheeler Power Co. · filed 1985-10-22(2)
In this case, the cause of action arose on October 4, 1980 — the date of the accident. Therefore, interest should have been awarded at the rate of eight percent per annum until the judgment is satisfied, as provided by statute on the date the cause of action arose.Read the full opinion on CourtListener →
The 1981 version of § 17.130(2) applies a twelve percent prejudgment interest rate to causes of action arising before July 1, 1987.
Jain v. McFarland · filed 1993-05-07(2)
Given that Ms. McFarland’s cause of action arose prior to July 1, 1987, we conclude that the district court properly applied the twelve percent prejudgment interest rate under the 1981 version of NRS 17.130(2).Read the full opinion on CourtListener →
Compound interest
Section 17.130 ordinarily provides for simple interest but permits a different interest rate specified in the judgment.
Halo Electronics, Inc. v. Pulse Electronics, Inc. · filed 2025-02-28(2)
The district court also did not err by awarding prejudg- ment interest “at the rate set forth in Nev. Rev. Stat. § 17.130, compounded annually.” App. 7.Read the full opinion on CourtListener →
18 more cases cited this section only in passing
These cases mention the section without interpreting it (a string cite, a footnote, background). Listed so you can see the full citation record, not just the annotated rulings.
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