Nevada Revised Statutes

Nev. Rev. Stat. § 18.015 (2026)

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

✓ current as of July 2026

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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, 305 P.3d 907 (Nev. 2013).

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Leventhal v. Black & LoBello, 305 P.3d 907 (Nev. 2013). · 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., 245 P.3d 542 (Nev. 2010). · 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 Jud. Dist. Court of the State of Nevada, 901 P.2d 643 (Nev. 1995). · 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 Jud. Dist. Court, 17 P.3d 1003 (Nev. 2001). · 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, 57 B.R. 672 (Bankr. D. Nev. 1986). · 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 Off. of Logar & Pulver, 157 P.3d 704 (Nev. 2007). · 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 Consol. Mining Co. v. Standish, 216 P.3d 779 (Nev. 2009). · 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., 799 P.2d 559 (Nev. 1990). · 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., 158 F.R.D. 666 (D. Nev. 1994). · 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, 647 P.2d 1004 (Wash. 1982). · cites it 2× “§ 37-61-420 (1981); Nev. Rev. Stat. § 18.015 (1979); N.H. Rev.”

Frank Settelmeyer & Sons, Inc. v. Smith & Harmer, Ltd., 197 P.3d 1051 (Nev. 2008). “31 NRS 18.015(3). 32 See generally Moses v. McGarvey, 614 P.”

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017). · cites it 84× “: NRS 18.015 provides for the enforcement of liens for attorney fees.”

Show all 53 citing cases →

— Nev. Rev. Stat. § 18.015(1) — 13 cases

Michel v. Eighth Jud. Dist. Court, 17 P.3d 1003 (Nev. 2001). “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., 245 P.3d 542 (Nev. 2010). ““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, 305 P.3d 907 (Nev. 2013). “: 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 Off. of Logar & Pulver, 157 P.3d 704 (Nev. 2007). “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.”

Figliuzzi v. Eighth Jud. Dist. Court of the State of Nevada Ex Rel. Cnty. of Clark, 890 P.2d 798 (Nev. 1995).

— Nev. Rev. Stat. § 18.015(1)(a) — 9 cases

Gonzales Vs. Campbell & Williams (Nev. 2021).

Mcdonald Carano Wilson LLP Vs. Bourassa Law Grp., LLC, 2015 NV 90 (Nev. 2015).

In Re: Discipline of Delmar Hardy (Nev. 2018).

Scammell (D. Nev. 2025).

Mcdonald Carano Wilson LLP Vs. Bourassa Law Grp., LLC, 2015 NV 90 (Nev. 2015).

— Nev. Rev. Stat. § 18.015(1)(b) — 4 cases

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017). “: NRS 18.015 provides for the enforcement of liens for attorney fees.”

Robert A. Slovak v. Wells Fargo Bank, N.A (D. Nev. 2025).

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017).

Scammell (D. Nev. 2025).

— Nev. Rev. Stat. § 18.015(2) — 16 cases

In Re Nicholson, 57 B.R. 672 (Bankr. D. Nev. 1986). “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., 158 F.R.D. 666 (D. Nev. 1994). “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., 799 P.2d 559 (Nev. 1990). “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.”

— Nev. Rev. Stat. § 18.015(3) — 21 cases

Argentena Consol. Mining Co. v. Standish, 216 P.3d 779 (Nev. 2009). “” 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., 197 P.3d 1051 (Nev. 2008). “31 NRS 18.015(3). 32 See generally Moses v. McGarvey, 614 P.”

— Nev. Rev. Stat. § 18.015(4) — 9 cases

Golightly & Vannah, Pllc Vs. Tj Allen, LLC, 2016 NV 41 (Nev. 2016).

Advanced Pre-Settlement Funding LLC v. Gazda & Tadayon (Nev. 2019).

Golightly & Vannah, Pllc Vs. Tj Allen, LLC, 2016 NV 41 (Nev. 2016).

— Nev. Rev. Stat. § 18.015(4)(a) — 11 cases

Imes v. Fox Rothschild, LLP (D. Nev. 2024).

Mcdonald Carano Wilson LLP Vs. Bourassa Law Grp., LLC, 2015 NV 90 (Nev. 2015).

Decesare v. Hutchison & Steffen, LLC (Nev. 2017).

In Re: Connell Living Trust (Nev. 2018).

Advanced Pre-Settlement Funding LLC v. Gazda & Tadayon (Nev. 2019).

— Nev. Rev. Stat. § 18.015(4)(b) — 4 cases

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017). “: NRS 18.015 provides for the enforcement of liens for attorney fees.”

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017).

Scammell (D. Nev. 2025).

Schwartzer v. Pisanelli Bice, Pllc (Bankr. D. Nev. 2023).

— Nev. Rev. Stat. § 18.015(5) — 1 case

— Nev. Rev. Stat. § 18.015(6) — 6 cases

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017). “: NRS 18.015 provides for the enforcement of liens for attorney fees.”

Fredianelli Vs. Martinez, 2017 NV 74 (Nev. 2017).

Scammell (D. Nev. 2025).

In Re: Discipline of Delmar Hardy (Nev. 2018).

Rios v. Wal-Mart Stores, Inc. (D. Nev. 2019).

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