Nevada Revised Statutes

Nev. Rev. Stat. § 104.2202 (2026)

Final expression: Parol or extrinsic evidence

✓ current as of July 2026
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NRS 104.2202  Final expression: Parol or extrinsic evidence.  Terms with respect to which the confirmatory memoranda of the parties agree or which are otherwise set forth in a record intended by the parties as a final expression of their agreement with respect to such terms as are included therein may not be contradicted by evidence of any prior agreement or of a contemporaneous oral agreement but may be explained or supplemented:

      1.  By course of performance, course of dealing or usage of trade (NRS 104.1303); and

      2.  By evidence of consistent additional terms unless the court finds the record to have been intended also as a complete and exclusive statement of the terms of the agreement.

      (Added to NRS by 1965, 787; A 2005, 849; 2023, 3182)

     

Notes of Decisions
Cited in 5 cases (1 in the last 5 years), 1987–2021 · leading case: Ringle v. Bruton, 86 P.3d 1032 (Nev. 2004).
Ringle v. Bruton, 86 P.3d 1032 (Nev. 2004). · cites it 2× “103, 107 , 590 P.2d 163, 165 (1979) (stating that parol evidence is admissible to determine intent when the written contract is ambiguous).”
Galardi v. Naples Polaris, L.L.C., 301 P.3d 364 (Nev. 2013). “2d 967, 971 (1995) (quoting NRS 104.2202(1)); see Las Vegas Sands, LLC v.”
Sierra Diesel Injection Serv. v. Burroughs Corp., 651 F. Supp. 1371 (D. Nev. 1987). · cites it 4× “PAROL EVIDENCE Defendant further argues that the plaintiffs allegations regarding any oral warranties or promises made before the contracts were signed must be disregarded by virtue of the parol evidence rule, codified at NRS § 104.2202. This section of the U.C.C.”
United Servs. Auto Ass'n v. Schlang, 894 P.2d 967 (Nev. 1995). · cites it 2× “]" NRS 104.2202(1). Also, where a contract is ambiguous, "parol evidence is admissible to explain its meaning.”
Gallina Fam. Bank Irrevocable Trust v. Lincoln Nat'l Life Ins. Co. (D. Nev. 2021). “§ 104.2202. 13 Nevada law allows the “course of performance, course of dealing, or usage of trade” 14 to “explain or supplement” a written agreement.”
— Nev. Rev. Stat. § 104.2202(1) — 2 cases
Galardi v. Naples Polaris, L.L.C., 301 P.3d 364 (Nev. 2013). “2d 967, 971 (1995) (quoting NRS 104.2202(1)); see Las Vegas Sands, LLC v.”
United Servs. Auto Ass'n v. Schlang, 894 P.2d 967 (Nev. 1995). “]" NRS 104.2202(1). Also, where a contract is ambiguous, "parol evidence is admissible to explain its meaning.”
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