Personal Injury Complaint - Auto Accident

DISCLAIMER
This template is provided for general informational purposes only and does not constitute legal advice. Use of this form does not create an attorney–client relationship. Nevada procedural rules, court-specific practices, and factual variations may require modifications. Consult a qualified Nevada-licensed attorney before filing.

PERSONAL INJURY COMPLAINT – AUTO ACCIDENT

(Nevada State Court – Fault/Tort Jurisdiction)

TABLE OF CONTENTS

1. Caption & Document Header

2. Preliminary Allegations
   2.1. Parties
   2.2. Jurisdiction & Venue

3. General Factual Allegations

4. Causes of Action
   4.1. Negligence
   4.2. Negligence Per Se (Optional)
   4.3. Respondeat Superior / Vicarious Liability (If Employer Involved)

5. Damages

6. Comparative Negligence Statement
7. Prayer for Relief
8. Jury Demand
9. Reservation of Rights
10. Verification (if required)
11. Certificate of Service

1. CAPTION & DOCUMENT HEADER

[COURT NAME]  
[COUNTY], STATE OF NEVADA  

[PLAINTIFF FULL LEGAL NAME],  
  Plaintiff,  

v.  

[DEFENDANT FULL LEGAL NAME],  
  Defendant.  

Case No.: [___]  
Dept. No.: [___]  

COMPLAINT FOR PERSONAL INJURIES (AUTO ACCIDENT)  
AND DEMAND FOR JURY TRIAL

2. PRELIMINARY ALLEGATIONS

2.1 Parties

1. Plaintiff [PLAINTIFF NAME] (“Plaintiff”) is, and at all relevant times was, a resident of [COUNTY], Nevada.
2. Upon information and belief, Defendant [DEFENDANT NAME] (“Defendant”) is, and at all relevant times was, a resident of [COUNTY/STATE], and may be served at [SERVICE ADDRESS].
3. [If corporate defendant] Defendant [DEFENDANT CORP.] is a [STATE] corporation authorized to do business in Nevada, with its principal place of business at [ADDRESS].

2.2 Jurisdiction & Venue

4. This Court has subject-matter jurisdiction pursuant to Nev. Const. art. 6 and NRS § 4.370 et seq.
5. Venue is proper in this County under NRS § 13.040 because the accident occurred, and/or Defendant resides, in this County.

3. GENERAL FACTUAL ALLEGATIONS

6. On [DATE], at approximately [TIME], Plaintiff was lawfully operating a [YEAR, MAKE, MODEL] motor vehicle traveling [DIRECTION] on [STREET/HIGHWAY] near [LOCATION], Clark County, Nevada.
7. At the same time and place, Defendant was operating a [YEAR, MAKE, MODEL] traveling [DIRECTION] on the same roadway.
8. Defendant negligently, recklessly, and carelessly [describe act/omission: e.g., failed to maintain lane, violated traffic signal, exceeded posted speed].
9. As a direct and proximate result, Defendant’s vehicle collided with Plaintiff’s vehicle, causing severe personal injuries and property damage to Plaintiff.
10. Plaintiff was transported to [MEDICAL FACILITY] and received medical treatment including [SURGERY/THERAPY/etc.].

4. CAUSES OF ACTION

4.1 First Cause of Action – Negligence

11. Plaintiff realleges paragraphs 1–10 as though fully set forth herein.
12. Defendant owed Plaintiff a duty of reasonable care to operate a motor vehicle in a safe and lawful manner.
13. Defendant breached that duty through the acts and omissions described above.
14. Defendant’s breach was the actual and proximate cause of Plaintiff’s injuries and damages.

4.2 Second Cause of Action – Negligence Per Se (Optional; cite exact statute violated)

15. Plaintiff realleges paragraphs 1–14.
16. At the time of the collision, Defendant violated [STATUTE/REGULATION e.g., NRS § 484B.257 – Failure to Maintain Lane].
17. Said statute was enacted to protect the class of persons including Plaintiff, and Plaintiff’s injuries are of the type the statute was designed to prevent.
18. Defendant’s statutory violation constitutes negligence per se.

4.3 Third Cause of Action – Respondeat Superior / Vicarious Liability (If applicable)

19. Plaintiff realleges paragraphs 1–18.
20. At the time of the collision, Defendant [EMPLOYEE NAME] was acting within the course and scope of employment with [EMPLOYER/DEFENDANT CORP.].
21. Therefore, [EMPLOYER] is vicariously liable for said negligence.

5. DAMAGES

22. As a direct and proximate result of Defendant’s negligence, Plaintiff suffered:
 a. Past and future medical expenses;
 b. Past and future lost wages and diminished earning capacity;
 c. Past and future pain, suffering, emotional distress, and loss of enjoyment of life;
 d. Property damage including loss of use;
 e. [Optional] Punitive damages for willful or wanton misconduct (e.g., driving under the influence); and
 f. Such other damages as may be proven at trial.

6. COMPARATIVE NEGLIGENCE STATEMENT

23. Pursuant to Nevada’s modified comparative negligence statute, Nev. Rev. Stat. § 41.141 (2023), Plaintiff’s recovery shall be diminished, but not barred, only in proportion to any percentage of negligence, if any, attributable to Plaintiff that is not greater than the negligence of Defendant.

7. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff and against Defendant as follows:
A. General and special damages in an amount to be proven at trial;
B. Punitive damages as allowed by law;
C. Pre- and post-judgment interest pursuant to NRS § 17.130;
D. Costs of suit herein incurred, and reasonable attorney’s fees as allowed by law; and
E. Such other and further relief as the Court deems just and proper.

8. JURY DEMAND

Plaintiff hereby demands trial by jury on all issues so triable as a matter of right pursuant to Nev. Const. art. 1, § 3.

9. RESERVATION OF RIGHTS

Plaintiff reserves the right to amend this Complaint to allege additional causes of action and parties as discovery proceeds.

10. VERIFICATION (if required by local rule)

I, [PLAINTIFF NAME], declare under penalty of perjury under the laws of the State of Nevada that I have read the foregoing Complaint and that the matters stated therein are true and correct of my own knowledge, except as to matters stated on information and belief, and as to those matters, I believe them to be true.

Executed this ___ day of __________, 20__, at [CITY], Nevada.

_________________________________  
[PLAINTIFF NAME]

11. CERTIFICATE OF SERVICE

I hereby certify that on the ___ day of __________, 20__, I served a true and correct copy of the foregoing COMPLAINT on all parties via [method: e-filing / hand-delivery / mail] in accordance with NRCP 5.

_________________________________  
[ATTORNEY NAME], Esq.
Counsel for Plaintiff
NV Bar No. [___]

SIGNATURE BLOCK

DATED: _____________, 20__.

Respectfully submitted,

[LAW FIRM NAME]

By: _____________________________  
   [ATTORNEY NAME], Esq.  
   Nevada Bar No. [___]  
   [ADDRESS]  
   [CITY, STATE ZIP]  
   Tel: [___] | Fax: [___]  
   Email: [___]  

Attorney for Plaintiff