Nevada Revised Statutes

Nev. Rev. Stat. § 11.070 (2026)

No cause of action effectual unless party or predecessor seized or possessed within 5 years

✓ current as of July 2026
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NRS 11.070  No cause of action effectual unless party or predecessor seized or possessed within 5 years.  No cause of action or defense to an action, founded upon the title to real property, or to rents or to services out of the same, shall be effectual, unless it appears that the person prosecuting the action or making the defense, or under whose title the action is prosecuted or the defense is made, or the ancestor, predecessor, or grantor of such person, was seized or possessed of the premises in question within 5 years before the committing of the act in respect to which said action is prosecuted or defense made.

      [1911 CPA § 10; RL § 4952; NCL § 8509]

     

Notes of Decisions
Cited in 39 cases (6 in the last 5 years), 1966–2023 · leading case: Carrington Mortg. Servs., LLC v. Tapestry At Town Ctr. Homeowners Ass'n, 381 F. Supp. 3d 1289 (D. Nev. 2019).
Carrington Mortg. Servs., LLC v. Tapestry At Town Ctr. Homeowners Ass'n, 381 F. Supp. 3d 1289 (D. Nev. 2019). · cites it 5× “220 and are therefore timely. The Court finds Carrington is not entitled to the five-year statute of limitations for certain quiet title actions pursuant to NRS 11.”
U.S. Bank Nat'l Ass'n v. SFR Invs. Pool 1, LLC, 376 F. Supp. 3d 1085 (D. Nev. 2019). · cites it 9× “14, 2018) (holding that the four-year catchall limitation period in § 11.220 applies to quiet-title claims by a lienholder seeking to determine whether an HOA sale extinguished its deed of trust).”
Weeping Hollow Avenue Trust v. Ashley Spencer, 831 F.3d 1110 (9th Cir. 2016). “Faced with the possibility that Spencer may later assert a claim to the property by arguing that the HOA foreclosure sale should be set aside on equitable grounds, Weeping Hollow reasonably chose to join her as a defendant in its action for quiet title and declaratory relief.”
Bank of N.Y. Mellon v. Ruddell, 380 F. Supp. 3d 1096 (D. Nev. 2019). · cites it 5× “The Court finds that BNY is not entitled to the five-year statute of limitations for certain quiet title actions pursuant to NRS 11.”
Fed. Hous. Fin. Agency, Home Loan Mortg. Corp. v. LN Mgmt. LLC, 369 F. Supp. 3d 1101 (D. Nev. 2019). · cites it 2× “070 because they are not founded upon title, rents, or services, but rather upon lien rights created by a deed of trust and further defined by federal statute (the federal foreclosure bar).”
Bank of Am., N.A. v. Woodcrest Homeowners Ass'n, 381 F. Supp. 3d 1280 (D. Nev. 2019). · cites it 5× “190(3)(a), or, at most, a four-year limitations period pursuant to NRS 11.220. 2 (Airmotive's MTD 6:1-8:11).”
Lanigir v. Arden, 409 P.2d 891 (Nev. 1966). · cites it 3× “Later they built a home, barn, corrals and fences at a total cost of about $33,000. Most of the time they ran livestock, raised, cut and baled hay.”
US Bank v. Thunder Props., Inc., 958 F.3d 794 (9th Cir. 2020). “See Nev. Rev. Stat § 11.070. Accordingly, U.S.”
Bank of New York Mellon v. Green Valley South Owners Ass'n No. 1 (D. Nev. 2019). · cites it 19× “May 30, 2019) (applying five-year statute of limitations to quiet title claim under NRS § 11.070); Newlands Asset 1 courts apply a five-year limitations period under NRS §§ 11.”
Kuptz-blinkinsop Vs. Blinkinsop, 2020 NV 40 (Nev. 2020). “See NRS 11.070 (providing that no cause of action founded upon the title to real property is effective unless the person bringing such action "was seized or possessed of the premises in question within 5 years before the committing of the act in respect to which said action is…”
Citibank, N.A. v. Rancho Las Brisas Master Homeowners Ass'n (D. Nev. 2019). · cites it 10× “If the quiet title claim is “founded upon the 5 title to real property or to rents or to services out of the same,” then NRS § 11.070 imposes a 6 five-year statute of limitations.”
SFR Investments Pool 1, LLC v. Bank of Am., N.A. (D. Nev. 2020). · cites it 9× “Nev. Rev. Stat. § 11.070 . This refers to the acquisition 19 of plaintiff’s claimed property rights, i.”
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