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21 Nevada opinions name it 1 courts 1957–2022 1 in the last five years
The cases below were cited by Nevada courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Daly v. Del E. Webb Corp.green2 sentences2013Webb Corp., 96 Nev. 359, 361 , 609 P.2d 319, 320 (1980) (“The parol evidence rule forbids the reception of evidence which would vary or contradict the contract, since all prior negotiations and agreements are deemed to have been merged therein.”). 2013Webb Corp., 96 Nev. 359, 361 , 609 P.2d 319, 320 (1980) (“The parol evidence rule forbids the reception of evidence which would vary or contradict the contract, since all prior negotiations and agreements are deemed to have been merged therein.”). | 3 | 3 |
Tallman v. First National Bankgreen2 sentences2016On its face, the schedule provided did not meet the requirements to trigger KB's self-help rights, 'We conclude that the parol evidence rule was not implicated here and accordingly decline to reach appellants' arguments that the parol evidence rule only applies to actions between parties to a contract and that this court should overrule Tallman v. First National Bank of Nevada, 66 Nev. 248 , 208 P.2d 302 (1949). 2016On its face, the schedule provided did not meet the requirements to trigger KB's self-help rights, 'We conclude that the parol evidence rule was not implicated here and accordingly decline to reach appellants' arguments that the parol evidence rule only applies to actions between parties to a contract and that this court should overrule Tallman v. First National Bank of Nevada, 66 Nev. 248 , 208 P.2d 302 (1949). | 2 | 4 |
Blumberg v. Palmgreen2 sentences2014Blumberg v. Palm, 56 N.W.2d 412, 415-16 (Minn. 1953). 2014Blumberg v. Palm, 56 N.W.2d 412, 415-16 (Minn. 1953). | 2 | 2 |
Ringle v. Brutongreen2 sentences2014The parol evidence rule precludes the admission of extrinsic "evidence that would change the contract terms when the terms of a written agreement are clear, definite, and unambiguous." Ringle v. Bruton, 120 Nev. 82, 91, 86 P.3d 1032, 1037 (2004). 2014The parol evidence rule precludes the admission of extrinsic "evidence that would change the contract terms when the terms of a written agreement are clear, definite, and unambiguous." Ringle v. Bruton, 120 Nev. 82, 91, 86 P.3d 1032, 1037 (2004). | 2 | 2 |
M.C. Multi-Family Development, L.L.C. v. Crestdale Associates, Ltd.green2 sentences2013Multi-Family Dev., 124 Nev. at 913-14 , 193 P.3d at 544-45 (providing that the district court’s application of the parol evidence rule is reviewed for an abuse of discretion). 2013Multi-Family Dev., 124 Nev. at 913-14 , 193 P.3d at 544-45 (providing that the district court’s application of the parol evidence rule is reviewed for an abuse of discretion). | 2 | 2 |
Western National Insurance v. Trentgreen2 sentences1963Child v. Miller, 74 Nev. 223 , 327 P.2d 342 ; Western National Insurance Co. v. Trent, 69 Nev. 239 , 247 P.2d 208 . 1963Child v. Miller, 74 Nev. 223 , 327 P.2d 342 ; Western National Insurance Co. v. Trent, 69 Nev. 239 , 247 P.2d 208 . | 1 | 2 |
9352 CRANESBILL TR. VS. WELLS FARGO BANK, N.A.green2 sentences2022See 9352 Cranesbill Tr. v. Wells Fargo Bank, 136 Nev. 76 , 82, 459 P.3d 227, 232 (2020) (providing that "this court will not address issues that the district court did not directly resolve"); Yellow Cab of Reno, Inc. v. Second Judicial Dist. 2022See 9352 Cranesbill Tr. v. Wells Fargo Bank, 136 Nev. 76, 82, 459 P.3d 227, 232 (2020) (providing that "this court will not address issues that the district court did not directly resolve"); Yellow Cab of Reno, Inc. v. Second Judicial Dist. | 1 | 1 |
Charleston Hill National Mines, Inc. v. Cloughgreen2 sentences2017Khan v. Bakhsh, 129 Nev. 554, 558 , 306 P.3d 411, 413 (2013) ("The parol evidence rule generally bars extrinsic evidence regarding prior or contemporaneous agreements that are contrary to the terms of an integrated contract."); Charleston Hill Nat'l Mines, Inc. v. Clough, 79 Nev. 182, 186 , 380 P.2d 458, 460 (1963) (stating that where the true consideration is stated in the note, parol evidence of an alternate form of consideration would be inadmissible). 2017Khan v. Bakhsh, 129 Nev. 554, 558 , 306 P.3d 411, 413 (2013) ("The parol evidence rule generally bars extrinsic evidence regarding prior or contemporaneous agreements that are contrary to the terms of an integrated contract."); Charleston Hill Nat'l Mines, Inc. v. Clough, 79 Nev. 182, 186 , 380 P.2d 458, 460 (1963) (stating that where the true consideration is stated in the note, parol evidence of an alternate form of consideration would be inadmissible). | 1 | 1 |
Khan v. Bakhshgreen2 sentences2017Khan v. Bakhsh, 129 Nev. 554, 558 , 306 P.3d 411, 413 (2013) ("The parol evidence rule generally bars extrinsic evidence regarding prior or contemporaneous agreements that are contrary to the terms of an integrated contract."); Charleston Hill Nat'l Mines, Inc. v. Clough, 79 Nev. 182, 186 , 380 P.2d 458, 460 (1963) (stating that where the true consideration is stated in the note, parol evidence of an alternate form of consideration would be inadmissible). 2017Khan v. Bakhsh, 129 Nev. 554, 558 , 306 P.3d 411, 413 (2013) ("The parol evidence rule generally bars extrinsic evidence regarding prior or contemporaneous agreements that are contrary to the terms of an integrated contract."); Charleston Hill Nat'l Mines, Inc. v. Clough, 79 Nev. 182, 186 , 380 P.2d 458, 460 (1963) (stating that where the true consideration is stated in the note, parol evidence of an alternate form of consideration would be inadmissible). | 1 | 1 |
Russ v. General Motors Corp.green2 sentences2015Russ v. General Motors Corp., 111 Nev. 1431, 1438-39 , 906 P.2d 718, 723 (1995). 2015Russ v. General Motors Corp., 111 Nev. 1431, 1438-39 , 906 P.2d 718, 723 (1995). | 1 | 1 |
Hotel Riviera, Inc. v. Torresgreen2 sentences2013Hotel Riviera, Inc. v. Torres, 97 Nev. 399, 403 , 632 P.2d 1155, 1158 (1981) (stating that this court may affirm a district court’s decision for different reasons than relied upon below). 3 We limit our discussion on this issue to the arguments raised by Frei on appeal and therefore assume without deciding that the parol evidence rule is available here. 2013Hotel Riviera, Inc. v. Torres, 97 Nev. 399, 403 , 632 P.2d 1155, 1158 (1981) (stating that this court may affirm a district court’s decision for different reasons than relied upon below). 3 We limit our discussion on this issue to the arguments raised by Frei on appeal and therefore assume without deciding that the parol evidence rule is available here. | 1 | 1 |
Estate of Sargavakgreen1 sentence2013See Ohanneson v. Lambrinidou (In re Sargavak’s Estate), 216 P.2d 850, 852 (Cal. 1950). | 1 | 1 |
Thomson v. Canyongreen2 sentences2013See Schneider, Smeltz, Ranney & LaFond, P.L.L., v. Kedia, 796 N.E.2d 553, 555-56 (Ohio Ct. App. 2003) (concluding in a legal malpractice case that the parol evidence rule would not preclude a client from introducing evidence that the document prepared by his attorney included different terms than those agreed to prior to execution); Thomson v. Canyon, 129 Cal. Rptr. 3d 525, 537 (Ct. App. 2011) (“The parol evidence rule prevents reconstruction of the parties’ contractual obligations; it does not immunize real estate agents, attorneys, or other professionals from liability arising from their mis 2013In rejecting this argument, we note that California law wavers in this position, as recent cases have held that the “key consideration in application of the parol evidence rule, whether invoked by a party or a stranger to the contract, is whether the extrinsic evidence is being offered to reconstruct the parties’ contractual obligations.” Thomson v. Canyon, 129 Cal. Rptr. 3d 525, 536 (Ct. App. 2011). | 1 | 1 |
Crow-Spieker 23 v. Robinsongreen2 sentences2013Crow-Spieker No. 23 v. Robinson, 97 Nev. 302, 305 , 629 P.2d 1198, 1199 (1981). 2013Crow-Spieker No. 23 v. Robinson, 97 Nev. 302, 305 , 629 P.2d 1198, 1199 (1981). | 1 | 1 |
Schneider, Smeltz, Ranney & Lafond, P.L.L. v. Kediagreen2 sentences2013See Schneider, Smeltz, Ranney & LaFond, P.L.L., v. Kedia, 796 N.E.2d 553, 555-56 (Ohio Ct. App. 2003) (concluding in a legal malpractice case that the parol evidence rule would not preclude a client from introducing evidence that the document prepared by his attorney included different terms than those agreed to prior to execution); Thomson v. Canyon, 129 Cal. Rptr. 3d 525, 537 (Ct. App. 2011) (“The parol evidence rule prevents reconstruction of the parties’ contractual obligations; it does not immunize real estate agents, attorneys, or other professionals from liability arising from their mis 2013See Schneider, Smeltz, Ranney & LaFond, P.L.L., v. Kedia, 796 N.E.2d 553, 555-56 (Ohio Ct. App. 2003) (concluding in a legal malpractice case that the parol evidence rule would not preclude a client from introducing evidence that the document prepared by his attorney included different terms than those agreed to prior to execution); Thomson v. Canyon, 129 Cal. Rptr. 3d 525, 537 (Ct. App. 2011) (“The parol evidence rule prevents reconstruction of the parties’ contractual obligations; it does not immunize real estate agents, attorneys, or other professionals from liability arising from their mis | 1 | 1 |
Massie v. Chatomgreen1 sentence2013Edwards v. Emperor’s Garden Rest., 122 Nev. 317 , 330 n.38, 130 P.3d 1280 , 1288 n.38 (2006) (noting that this court need not consider an issue not cogently argued or supported by relevant legal authority). 4 Finally, Frei cites Massie v. Chatom, 127 P. 56, 57 (Cal. 1912), for the proposition that the parol evidence rule only applies to actions between parties to the contract or their privies. | 1 | 1 |
Sherrodd, Inc. v. Morrison-Knudsen Co.green1 sentence2012Such proof is not permitted.”); Sherrodd, Inc. v. Morrison-Knudsen Co., 815 P.2d 1135, 1137 (Mont. 1991) (providing that the exception made to the parol evidence rule when fraud is alleged “only applies when the alleged fraud does not relate directly to the subject of the contract. | 1 | 1 |
Havas v. Algergreen2 sentences1978See Havas v. Alger, 85 Nev. 627 , 461 P.2d 857 (1969), involving appellant Vic Havas’s fraudulent procurement of an automobile sales contract. 1978See Havas v. Alger, 85 Nev. 627 , 461 P.2d 857 (1969), involving appellant Vic Havas’s fraudulent procurement of an automobile sales contract. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Nevada. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Child v. George Miller, Inc.
green
2 sentences1980Our decision in Child v. Miller, 74 Nev. 223 , 327 P.2d 342 (1958), allowed the reception of evidence which did not contradict the written instrument, but which referred to the very existence of the contract and tended to show that no valid and effective contract ever existed. 1980Our decision in Child v. Miller, 74 Nev. 223 , 327 P.2d 342 (1958), allowed the reception of evidence which did not contradict the written instrument, but which referred to the very existence of the contract and tended to show that no valid and effective contract ever existed. | 2 | 1963–1980 |
Dixon v. Miller
green
2 sentences1972While a showing of failure of consideration does not contravene the parol evidence rule, Dixon v. Miller, 43 Nev. 280 , 184 P. 926 (1919), the proffered evidence would not have shown want or failure of consideration. 1972While a showing of failure of consideration does not contravene the parol evidence rule, Dixon v. Miller, 43 Nev. 280 , 184 P. 926 (1919), the proffered evidence would not have shown want or failure of consideration. | 2 | 1963–1972 |
Edwards v. Emperor's Garden Restaurant
green
2 sentences2013Edwards v. Emperor’s Garden Rest., 122 Nev. 317 , 330 n.38, 130 P.3d 1280 , 1288 n.38 (2006) (noting that this court need not consider an issue not cogently argued or supported by relevant legal authority). 4 Finally, Frei cites Massie v. Chatom, 127 P. 56, 57 (Cal. 1912), for the proposition that the parol evidence rule only applies to actions between parties to the contract or their privies. 2013Edwards v. Emperor’s Garden Rest., 122 Nev. 317 , 330 n.38, 130 P.3d 1280 , 1288 n.38 (2006) (noting that this court need not consider an issue not cogently argued or supported by relevant legal authority). 4 Finally, Frei cites Massie v. Chatom, 127 P. 56, 57 (Cal. 1912), for the proposition that the parol evidence rule only applies to actions between parties to the contract or their privies. | 1 | 2013–2013 |
Bionghi v. Metropolitan Water District
green
1 sentence2001Bionghi, 83 Cal. Rptr. 2d at 394 . | 1 | 2001–2001 |
Silver Dollar Club v. Cosgriff Neon Company
green
2 sentences1987Silver Dollar Club v. Cosgriff Neon, 80 Nev. 108 , 389 P.2d 923 (1964). 3 The statute was amended between the initiation of this lawsuit and entry of judgment. 1987Silver Dollar Club v. Cosgriff Neon, 80 Nev. 108 , 389 P.2d 923 (1964). 3 The statute was amended between the initiation of this lawsuit and entry of judgment. | 1 | 1987–1987 |
Schieve v. Warren
green
2 sentences1980Schieve v. Warren, 87 Nev. 42 , 482 P.2d 303 (1971); Tallman v. First National Bank, 66 Nev. 248 , 208 P.2d 302 (1949). 1980Schieve v. Warren, 87 Nev. 42 , 482 P.2d 303 (1971); Tallman v. First National Bank, 66 Nev. 248 , 208 P.2d 302 (1949). | 1 | 1980–1980 |
Alexander v. Simmons
green
2 sentences1975Alexander v. Simmons, 90 Nev. 23 , 518 P.2d 160 (1974), citing Douglass v. Thompson, 35 Nev. 196 , 127 P. 561 (1912). 1975Alexander v. Simmons, 90 Nev. 23 , 518 P.2d 160 (1974), citing Douglass v. Thompson, 35 Nev. 196 , 127 P. 561 (1912). | 1 | 1975–1975 |
Douglass v. Thompson
neutral
1 sentence1975Alexander v. Simmons, 90 Nev. 23 , 518 P.2d 160 (1974), citing Douglass v. Thompson, 35 Nev. 196 , 127 P. 561 (1912). | 1 | 1975–1975 |
Friendly Irishman, Inc. v. Ronnow
green
1 sentence1969The parol evidence rule, then, does not apply.” 74 Nev. at 318-19 . | 1 | 1969–1969 |
Herrman v. Combs
green
2 sentences1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . 1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . | 1 | 1963–1963 |
Haase v. Ramsay
green
2 sentences1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . 1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . | 1 | 1963–1963 |
First State Bank of Gowen v. Miller
neutral
2 sentences1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . 1963Mills v. Bonin, 239 N.C. 498 , 80 S.E.2d 365 ; First State Bank v. Miller, 118 Okl. 49 , 246 P. 591 ; Herrman v. Combs, 119 Md. 41 , 85 A. 1044 ; Haase v. Ramsay, 10 Wis.2d 220 , 102 N.W.2d 226 . | 1 | 1963–1963 |
| Mills v. Bonin green | 1 | 1963–1963 |
| C. G. Gunter, Inc. v. Hindman neutral | 1 | 1963–1963 |
| Gladden v. Keistler green | 1 | 1963–1963 |
| Evans v. Lee green | 1 | 1957–1957 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.