Nev. Rev. Stat. § 18.015

Lien for attorney’s fees: Amount; perfection; enforcement

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NRS 18.015  Lien for attorney’s fees: Amount; perfection; enforcement.

      1.  An attorney at law shall have a lien:

      (a) Upon any claim, demand or cause of action, including any claim for unliquidated damages, which has been placed in the attorney’s hands by a client for suit or collection, or upon which a suit or other action has been instituted.

      (b) In any civil action, upon any file or other property properly left in the possession of the attorney by a client.

      2.  A lien pursuant to subsection 1 is for the amount of any fee which has been agreed upon by the attorney and client. In the absence of an agreement, the lien is for a reasonable fee for the services which the attorney has rendered for the client.

      3.  An attorney perfects a lien described in subsection 1 by serving notice in writing, in person or by certified mail, return receipt requested, upon his or her client and, if applicable, upon the party against whom the client has a cause of action, claiming the lien and stating the amount of the lien.

      4.  A lien pursuant to:

      (a) Paragraph (a) of subsection 1 attaches to any verdict, judgment or decree entered and to any money or property which is recovered on account of the suit or other action; and

      (b) Paragraph (b) of subsection 1 attaches to any file or other property properly left in the possession of the attorney by his or her client, including, without limitation, copies of the attorney’s file if the original documents received from the client have been returned to the client, and authorizes the attorney to retain any such file or property until such time as an adjudication is made pursuant to subsection 6,

Ê from the time of service of the notices required by this section.

      5.  A lien pursuant to paragraph (b) of subsection 1 must not be construed as inconsistent with the attorney’s professional responsibilities to the client.

      6.  On motion filed by an attorney having a lien under this section, the attorney’s client or any party who has been served with notice of the lien, the court shall, after 5 days’ notice to all interested parties, adjudicate the rights of the attorney, client or other parties and enforce the lien.

      7.  Collection of attorney’s fees by a lien under this section may be utilized with, after or independently of any other method of collection.

      (Added to NRS by 1977, 773; A 2013, 271)

     

Notes of Decisions
Cited in 53 cases (11 in the last 5 years), 1982–2025 · leading case: Leventhal v. Black & LoBello
Leventhal v. Black & LoBello (2013) nev · cites it 27× “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
Schuck v. Signature Flight Support of Nevada, Inc. (2010) nev · cites it 7× ““The lien attaches to any verdict, judgment or decree entered and to any money or property which is recovered on account of the suit or other action .”
Harvey L. Lerer, Inc. v. Eighth Judicial District Court of the State of Nevada (1995) nev · cites it 22× “On September 4, 1992, Smith filed and served upon all counsel and the district court a motion to adjudicate an attorney's lien, pursuant to NRS 18.015. In his affidavit in support of his motion, Smith requested that the district court award him a "reasonable attorney's fee in…”
Michel v. Eighth Judicial District Court (2001) nev · cites it 12× “Priority of attorney liens NRS 18.015 provides an attorney with a lien for attorney fees against any settlement or judgment obtained: 2 1.”
In Re Nicholson (1986) nvb · cites it 12× “The Bankruptcy Code grants the bankruptcy trustee power to avoid unperfected or unenforceable statutory liens. The Court must, therefore, conclude that the movant’s attorney’s lien is avoidable under § 545(2).”
Bero-Wachs v. Law Office of Logar & Pulver (2007) nev · cites it 8× “090 exempts alimony and certain retirement accounts from execution, NRS 18.015 allows an attorney to place a lien upon his client’s claim or cause of action in the amount of a reasonable fee for the attorney’s services.”
Argentena Consolidated Mining Co. v. Standish (2009) nev · cites it 3× “” Because Argentena did not seek or obtain any affirmative recovery in the underlying action, it argues that there could be no basis for a charging lien.”
John W. Muije, Ltd. v. a North Las Vegas Cab Co. (1990) nev · cites it 6× “Before the jury’s verdict, Muije filed an attorney’s lien pursuant to NRS 18.015. After trial, Cab Company filed a motion for attorney’s fees and costs.”
Schlang v. Key Airlines, Inc. (1994) nvd · cites it 6× “The first Notice (#348), filed on September 18, 1992, declared an attorney’s lien for attorney’s fees and costs, which by contract amounted to 50% of all amounts recovered, and costs expended or incurred up to that date. The second Notice (#375), filed on October 26, 1993, does…”
Ross v. Scannell (1982) wash · cites it 2× “§ 37-61-420 (1981); Nev. Rev. Stat. § 18.015 (1979); N.H. Rev.”
Frank Settelmeyer & Sons, Inc. v. Smith & Harmer, Ltd. (2008) nev “31 NRS 18.015(3). 32 See generally Moses v. McGarvey, 614 P.”
FREDIANELLI VS. MARTINEZ (2017) nev · cites it 84× “: NRS 18.015 provides for the enforcement of liens for attorney fees.”
— Nev. Rev. Stat. § 18.015(1) — 13 cases
Michel v. Eighth Judicial District Court (2001) nev “Priority of attorney liens NRS 18.015 provides an attorney with a lien for attorney fees against any settlement or judgment obtained: 2 1.”
Schuck v. Signature Flight Support of Nevada, Inc. (2010) nev ““The lien attaches to any verdict, judgment or decree entered and to any money or property which is recovered on account of the suit or other action .”
Leventhal v. Black & LoBello (2013) nev “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
Bero-Wachs v. Law Office of Logar & Pulver (2007) nev “090 exempts alimony and certain retirement accounts from execution, NRS 18.015 allows an attorney to place a lien upon his client’s claim or cause of action in the amount of a reasonable fee for the attorney’s services.”
— Nev. Rev. Stat. § 18.015(1)(a) — 9 cases
— Nev. Rev. Stat. § 18.015(1)(b) — 4 cases
FREDIANELLI VS. MARTINEZ (2017) nev “: NRS 18.015 provides for the enforcement of liens for attorney fees.”
— Nev. Rev. Stat. § 18.015(2) — 16 cases
Leventhal v. Black & LoBello (2013) nev “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
In Re Nicholson (1986) nvb “The Bankruptcy Code grants the bankruptcy trustee power to avoid unperfected or unenforceable statutory liens. The Court must, therefore, conclude that the movant’s attorney’s lien is avoidable under § 545(2).”
Schlang v. Key Airlines, Inc. (1994) nvd “The first Notice (#348), filed on September 18, 1992, declared an attorney’s lien for attorney’s fees and costs, which by contract amounted to 50% of all amounts recovered, and costs expended or incurred up to that date. The second Notice (#375), filed on October 26, 1993, does…”
John W. Muije, Ltd. v. a North Las Vegas Cab Co. (1990) nev “Before the jury’s verdict, Muije filed an attorney’s lien pursuant to NRS 18.015. After trial, Cab Company filed a motion for attorney’s fees and costs.”
Michel v. Eighth Judicial District Court (2001) nev “Priority of attorney liens NRS 18.015 provides an attorney with a lien for attorney fees against any settlement or judgment obtained: 2 1.”
— Nev. Rev. Stat. § 18.015(3) — 21 cases
Leventhal v. Black & LoBello (2013) nev “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
Schuck v. Signature Flight Support of Nevada, Inc. (2010) nev ““The lien attaches to any verdict, judgment or decree entered and to any money or property which is recovered on account of the suit or other action .”
Argentena Consolidated Mining Co. v. Standish (2009) nev “” Because Argentena did not seek or obtain any affirmative recovery in the underlying action, it argues that there could be no basis for a charging lien.”
Frank Settelmeyer & Sons, Inc. v. Smith & Harmer, Ltd. (2008) nev “31 NRS 18.015(3). 32 See generally Moses v. McGarvey, 614 P.”
Bero-Wachs v. Law Office of Logar & Pulver (2007) nev “090 exempts alimony and certain retirement accounts from execution, NRS 18.015 allows an attorney to place a lien upon his client’s claim or cause of action in the amount of a reasonable fee for the attorney’s services.”
— Nev. Rev. Stat. § 18.015(4) — 9 cases
Leventhal v. Black & LoBello (2013) nev “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
— Nev. Rev. Stat. § 18.015(4)(a) — 11 cases
— Nev. Rev. Stat. § 18.015(4)(b) — 4 cases
FREDIANELLI VS. MARTINEZ (2017) nev “: NRS 18.015 provides for the enforcement of liens for attorney fees.”
— Nev. Rev. Stat. § 18.015(5) — 1 case
Leventhal v. Black & LoBello (2013) nev “: This is an appeal from an order adjudicating a law firm’s charging lien for fees against its former client under NRS 18.015. The firm did not serve the statutory notices required to perfect its lien until the case was over.”
— Nev. Rev. Stat. § 18.015(6) — 6 cases
FREDIANELLI VS. MARTINEZ (2017) nev “: NRS 18.015 provides for the enforcement of liens for attorney fees.”
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