Nevada Revised Statutes

Nev. Rev. Stat. § 209.451 (2026)

Forfeiture and restoration of credits

✓ current as of July 2026
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NRS 209.451  Forfeiture and restoration of credits.

      1.  If an offender:

      (a) Commits an assault upon his or her keeper or a foreman, officer, offender or other person, or otherwise endangers life;

      (b) Is guilty of a flagrant disregard of the regulations of the Department or of the terms and conditions of his or her residential confinement;

      (c) Commits a misdemeanor, gross misdemeanor or felony; or

      (d) In a civil action, in state or federal court, is found by the court to have presented a pleading, written motion or other document in writing to the court which:

             (1) Contains a claim or defense that is included for an improper purpose, including, without limitation, for the purpose of harassing the offender’s opponent, causing unnecessary delay in the litigation or increasing the cost of the litigation;

             (2) Contains a claim, defense or other argument which is not warranted by existing law or by a reasonable argument for a change in existing law or a change in the interpretation of existing law; or

             (3) Contains allegations or information presented as fact for which evidentiary support is not available or is not likely to be discovered after further investigation,

Ê the offender forfeits all deductions of time earned by the offender before the commission of that offense or act, or forfeits such part of those deductions as the Director considers just.

      2.  If an offender commits a serious violation of the regulations of the Department or of the terms and conditions of his or her residential confinement or if an offender violates subsection 4 of NRS 209.367, the offender may forfeit all or part of such deductions, in the discretion of the Director.

      3.  A forfeiture may be made only by the Director after proof of the commission of an act prohibited pursuant to this section and notice to the offender in the manner prescribed in the regulations of the Department. The decision of the Director regarding a forfeiture is final.

      4.  The Director may restore credits forfeited for such reasons as the Director considers proper.

      5.  As used in this section, “civil action” includes a petition for a writ of habeas corpus filed in state or federal court.

      (Added to NRS by 1977, 852; A 1985, 687, 1926; 1991, 1410; 1995, 210; 1997, 1642; 1999, 146)

     

Notes of Decisions
Cited in 13 cases (1 in the last 5 years), 1998–2026 · leading case: Hosier v. State, 117 P.3d 212 (Nev. 2005).
Hosier v. State, 117 P.3d 212 (Nev. 2005). · cites it 2× “10 NRS 209.451(1)(d). A petition for a writ of habeas corpus is a “civil action” for the purposes of this statute.”
Braunstein (Steven) v. Dist. Ct. (State) (Nev. 2015). · cites it 8× “63270, 63411 (Order Denying Petitions, July 24, 2013), that statutory credits may be forfeited pursuant to NRS 209.451 if he continues to file frivolous documents in a civil action.”
Dotson v. State, 958 P.2d 81 (Nev. 1998). · cites it 7× “Appellant does not challenge the district court’s determination to dismiss her habeas corpus petition.”
Braunstein (Steven) v. the Eighth Jud. Dist. Ct. (Nev. 2014). · cites it 4× “3 See NRS 209.451. A petition for an injunction against judgment is a civil action.”
Jones v. Eighth Jud. Dist. Ct., 2014 NV 53 (Nev. 2014). · cites it 4× “In the motion, the State did not mention a restrictive order or Jordan; rather, the State asked the court to sanction Jones' allegedly vexatious litigation practices pursuant to NRS 209.451, which provides for the forfeiture of credits.”
Alexander (Demetri) v. State (Nev. 2017). · cites it 2× “1 The district court had jurisdiction to enter the challenged order, see NRS 209.451(1)(d), so prohibition is not available.”
Trevino, Sr. (Franklin) v. Warden (Nev. 2019). · cites it 2× “See NRS 209.451(1)(d) (providing that in certain circumstances an offender may forfeit credits based on a written SUPREME COURT OF NEVADA 2 (01 1947A 44424t.”
Hanes (Jonathan) v. Warden (Nev. 2019). · cites it 2× “See NRS 209.451(1)(d) (providing that in certain circumstances an offender may forfeit credits based on a written document that he or she has presented to a court in a "civil action"); NRS 209.”
Thomas (Christopher) v. Warden (Nev. 2016). “70301 (Order Denying Petition, June 16, 2016). Petitioner is cautioned that statutory credits may be forfeited if he files frivolous documents in a SUPREME COURT OF NEVADA (0) 1947A ea:, civil action.”
Crawley v. Williams (9th Cir. 2026). “4465 (7)(a) (providing that credits earned “[m]ust be deducted from the maximum term or the maximum aggregate term imposed by the sentence”); Nev. Rev. Stat. § 209.451 (limiting circumstances under which an incarcerated person forfeits their good time credits); Sandin v.”
Parra (Julio) v. Warden (Nev. 2013). “pursuant to NRS 209.451(1)(d). Therefore, the district court did not err in denying the petition, and we ORDER the judgment of the district court AFFIRMED.”
Braunstein (Steven) v. Dist. Ct. (State) (Nev. 2013). “53127 (Order Denying Petition, February 4, 2009); Braunstein v.”
— Nev. Rev. Stat. § 209.451(1)(d) — 6 cases
Hosier v. State, 117 P.3d 212 (Nev. 2005). “10 NRS 209.451(1)(d). A petition for a writ of habeas corpus is a “civil action” for the purposes of this statute.”
Trevino, Sr. (Franklin) v. Warden (Nev. 2019). “See NRS 209.451(1)(d) (providing that in certain circumstances an offender may forfeit credits based on a written SUPREME COURT OF NEVADA 2 (01 1947A 44424t.”
Hanes (Jonathan) v. Warden (Nev. 2019). “See NRS 209.451(1)(d) (providing that in certain circumstances an offender may forfeit credits based on a written document that he or she has presented to a court in a "civil action"); NRS 209.”
Jones v. Eighth Jud. Dist. Ct., 2014 NV 53 (Nev. 2014). “In the motion, the State did not mention a restrictive order or Jordan; rather, the State asked the court to sanction Jones' allegedly vexatious litigation practices pursuant to NRS 209.451, which provides for the forfeiture of credits.”
Alexander (Demetri) v. State (Nev. 2017). “1 The district court had jurisdiction to enter the challenged order, see NRS 209.451(1)(d), so prohibition is not available.”
— Nev. Rev. Stat. § 209.451(3) — 2 cases
Braunstein (Steven) v. the Eighth Jud. Dist. Ct. (Nev. 2014). “3 See NRS 209.451. A petition for an injunction against judgment is a civil action.”
Braunstein (Steven) v. Dist. Ct. (State) (Nev. 2015). “63270, 63411 (Order Denying Petitions, July 24, 2013), that statutory credits may be forfeited pursuant to NRS 209.451 if he continues to file frivolous documents in a civil action.”
— Nev. Rev. Stat. § 209.451(5) — 2 cases
Hosier v. State, 117 P.3d 212 (Nev. 2005). “10 NRS 209.451(1)(d). A petition for a writ of habeas corpus is a “civil action” for the purposes of this statute.”
Alexander (Demetri) v. State (Nev. 2017). “1 The district court had jurisdiction to enter the challenged order, see NRS 209.451(1)(d), so prohibition is not available.”
— Nev. Rev. Stat. § 209.451(l)(d)(2) — 1 case
Dotson v. State, 958 P.2d 81 (Nev. 1998). “Appellant does not challenge the district court’s determination to dismiss her habeas corpus petition.”
— Nev. Rev. Stat. § 209.451(l)(d)(3) — 1 case
Dotson v. State, 958 P.2d 81 (Nev. 1998). “Appellant does not challenge the district court’s determination to dismiss her habeas corpus petition.”
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