Nevada Revised Statutes

Nev. Rev. Stat. § 128.106 (2026)

Specific considerations in determining neglect by or unfitness of parent

✓ current as of July 2026 Cite as: Nev. Rev. Stat. § 128.106 (2026)
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NRS 128.106  Specific considerations in determining neglect by or unfitness of parent.

      1.  In determining neglect by or unfitness of a parent, the court shall consider, without limitation, the following conditions which may diminish suitability as a parent:

      (a) Emotional illness, mental illness or mental deficiency of the parent which renders the parent consistently unable to care for the immediate and continuing physical or psychological needs of the child for extended periods of time. The provisions contained in NRS 128.109 apply to the case if the child has been placed outside his or her home pursuant to chapter 432B of NRS.

      (b) Conduct toward a child of a physically, emotionally or sexually cruel or abusive nature.

      (c) Conduct that violates any provision of NRS 200.463, 200.4631, 200.464 or 200.465.

      (d) Excessive use of intoxicating liquors, controlled substances or dangerous drugs which renders the parent consistently unable to care for the child.

      (e) Repeated or continuous failure by the parent, although physically and financially able, to provide the child with adequate food, clothing, shelter, education or other care and control necessary for the child’s physical, mental and emotional health and development, but a person who, legitimately practicing his or her religious beliefs, does not provide specified medical treatment for a child is not for that reason alone a negligent parent.

      (f) Conviction of the parent for commission of a felony, if the facts of the crime are of such a nature as to indicate the unfitness of the parent to provide adequate care and control to the extent necessary for the child’s physical, mental or emotional health and development.

      (g) Whether the child, a sibling of the child or another child in the care of the parent suffered a physical injury resulting in substantial bodily harm, a near fatality or fatality for which the parent has no reasonable explanation and for which there is evidence that such physical injury or death would not have occurred absent abuse or neglect of the child by the parent.

      (h) Inability of appropriate public or private agencies to reunite the family despite reasonable efforts on the part of the agencies.

      2.  As used in this section, “near fatality” has the meaning ascribed to it in NRS 432B.175.

      (Added to NRS by 1981, 1751; A 1989, 1187; 1995, 361; 2005, 89; 2013, 1856; 2015, 1185)

     

Notes of Decisions
Cited in 61 cases (5 in the last 5 years), 1984–2025 · leading case: Champagne v. WELFARE DIV. OF NEV. STATE DEPT.
Champagne v. WELFARE DIV. OF NEV. STATE DEPT. (1984) nev · cites it 9× “” The “considerations” set forth in the section include abandonment, neglect, unfitness of the parent, child abuse and a rather hazy, probably redundant consideration phrased as “[o]nly token efforts by the parent” to avoid or prevent abandonment, neglect, unfitness or abuse.”
Quiana M. B. v. State Department of Family Services (2012) nev · cites it 4× “Arthur argues that (1) the family division of the district court improperly admitted the entire “J” file even though it contained hearsay and dou *468 ble hearsay statements, (2) the family division of the district court failed to consider the factors contained in NRS 128.106…”
Roe v. Roe (2023) nevapp · cites it 6× “" When a parent has been determined by a district court to be unfit or neglectful, see NRS 128.106, this can be a basis for terminating parental rights.”
Vincent L. G. v. State Division of Child & Family Services, Department of Human Resources (2004) nev · cites it 3× “NRS 128.106 sets forth specific considerations in determining neglect or unfitness.”
Weinper v. Nevada State Department of Human Resources (1996) nev · cites it 6× “Among these is "[e]xcessive use of intoxicating liquors, controlled substances or dangerous drugs which renders the parent consistently unable to care for the child." NRS 128.106(4). The district court specifically found that Weinper was unfit as a parent because of his "drug…”
Bush v. State, Department of Human Resources (1996) nev · cites it 6× “For determining parental unfitness, NRS 128.106 provides the following guidance: In determining neglect by or unfitness of a parent, the court shall consider, without limitation, the following conditions which may diminish suitability as a parent: 1.”
Dawn M. v. Nevada State Division of Child & Family Services (2009) nev · cites it 3× “NRS 128.106(4) provides that when determining neglect, the court shall consider whether excessive drug and alcohol use interfered with the parent’s ability to care for the child.”
Letesheia O. v. State, Division of Child & Family Services (2005) nev · cites it 2× “Again, whether or not Letesheia had received assistance of counsel, NRS 128.106(6) dictates that the court consider details of her previous convictions.”
Richard J. K. v. State, Division of Child & Family Services (2002) nev · cites it 2× “The district court found Richard unfit pursuant to NRS 128.106(6), based upon his convictions for domestic violence and the possibility that his children might become victims of his violent outbursts.”
Matter of Parental Rights as to Bow (1997) nev · cites it 4× “The district court concluded that Recodo was an unfit parent as defined by NRS 128.”
Matter of Parental Rights as to QLR (2002) nev · cites it 2× “[11] See NRS 128.106(6). This NRS statutory provision, entitled "Specific considerations in determining neglect by or unfitness of parent," is the only parental rights termination provision that directly addresses incarceration.”
Matter of Parental Rights as to DRH (2004) nev · cites it 3× “106(4) provides that "[e]xcessive use of intoxicating liquors, controlled substances or dangerous drugs which renders the parent consistently unable to care for the child," is one such factor.”
— Nev. Rev. Stat. § 128.106(1) — 8 cases
Champagne v. WELFARE DIV. OF NEV. STATE DEPT. (1984) nev “” The “considerations” set forth in the section include abandonment, neglect, unfitness of the parent, child abuse and a rather hazy, probably redundant consideration phrased as “[o]nly token efforts by the parent” to avoid or prevent abandonment, neglect, unfitness or abuse.”
— Nev. Rev. Stat. § 128.106(1)(a) — 7 cases
— Nev. Rev. Stat. § 128.106(1)(b) — 3 cases
— Nev. Rev. Stat. § 128.106(1)(d) — 3 cases
— Nev. Rev. Stat. § 128.106(1)(e) — 3 cases
— Nev. Rev. Stat. § 128.106(1)(f) — 4 cases
— Nev. Rev. Stat. § 128.106(1)(h) — 1 case
— Nev. Rev. Stat. § 128.106(2) — 1 case
— Nev. Rev. Stat. § 128.106(4) — 6 cases
Vincent L. G. v. State Division of Child & Family Services, Department of Human Resources (2004) nev “NRS 128.106 sets forth specific considerations in determining neglect or unfitness.”
Weinper v. Nevada State Department of Human Resources (1996) nev “Among these is "[e]xcessive use of intoxicating liquors, controlled substances or dangerous drugs which renders the parent consistently unable to care for the child." NRS 128.106(4). The district court specifically found that Weinper was unfit as a parent because of his "drug…”
Dawn M. v. Nevada State Division of Child & Family Services (2009) nev “NRS 128.106(4) provides that when determining neglect, the court shall consider whether excessive drug and alcohol use interfered with the parent’s ability to care for the child.”
Matter of Parental Rights as to DRH (2004) nev “106(4) provides that "[e]xcessive use of intoxicating liquors, controlled substances or dangerous drugs which renders the parent consistently unable to care for the child," is one such factor.”
In Re Nj (2009) nev
— Nev. Rev. Stat. § 128.106(5) — 1 case
— Nev. Rev. Stat. § 128.106(6) — 15 cases
Letesheia O. v. State, Division of Child & Family Services (2005) nev “Again, whether or not Letesheia had received assistance of counsel, NRS 128.106(6) dictates that the court consider details of her previous convictions.”
Richard J. K. v. State, Division of Child & Family Services (2002) nev “The district court found Richard unfit pursuant to NRS 128.106(6), based upon his convictions for domestic violence and the possibility that his children might become victims of his violent outbursts.”
Matter of Parental Rights as to QLR (2002) nev “[11] See NRS 128.106(6). This NRS statutory provision, entitled "Specific considerations in determining neglect by or unfitness of parent," is the only parental rights termination provision that directly addresses incarceration.”
Vincent L. G. v. State Division of Child & Family Services, Department of Human Resources (2004) nev “NRS 128.106 sets forth specific considerations in determining neglect or unfitness.”
Dawn M. v. Nevada State Division of Child & Family Services (2009) nev “NRS 128.106(4) provides that when determining neglect, the court shall consider whether excessive drug and alcohol use interfered with the parent’s ability to care for the child.”
— Nev. Rev. Stat. § 128.106(8) — 4 cases
Matter of Parental Rights as to Bow (1997) nev “The district court concluded that Recodo was an unfit parent as defined by NRS 128.”
Dawn M. v. Nevada State Division of Child & Family Services (2009) nev “NRS 128.106(4) provides that when determining neglect, the court shall consider whether excessive drug and alcohol use interfered with the parent’s ability to care for the child.”
In Re Nj (2009) nev
— Nev. Rev. Stat. § 128.106(a) — 1 case
Roe v. Roe (2023) nevapp “" When a parent has been determined by a district court to be unfit or neglectful, see NRS 128.106, this can be a basis for terminating parental rights.”
— Nev. Rev. Stat. § 128.106(b) — 1 case
— Nev. Rev. Stat. § 128.106(l)(a) — 1 case
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