Nev. Rev. Stat. » NRS: CHAPTER 213 - PARDONS AND PAROLES; REMISSIONS OF FINES AND COMMUTATIONS OF PUNISHMENTS
Nevada Revised Statutes

Nev. Rev. Stat. § 213.12135 (2026)

Eligibility for parole of prisoner sentenced as adult for offense committed when prisoner was less than 18 years of age

✓ current as of July 2026
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NRS 213.12135  Eligibility for parole of prisoner sentenced as adult for offense committed when prisoner was less than 18 years of age.

      1.  Notwithstanding any other provision of law, except as otherwise provided in subsection 2 or unless a prisoner is subject to earlier eligibility for parole pursuant to any other provision of law, a prisoner who was sentenced as an adult for an offense that was committed when he or she was less than 18 years of age is eligible for parole as follows:

      (a) For a prisoner who is serving a period of incarceration for having been convicted of an offense or offenses that did not result in the death of a victim, after the prisoner has served 15 calendar years of incarceration, including any time served in a county jail.

      (b) For a prisoner who is serving a period of incarceration for having been convicted of an offense or offenses that resulted in the death of only one victim, after the prisoner has served 20 calendar years of incarceration, including any time served in a county jail.

      2.  The provisions of this section do not apply to a prisoner who is serving a period of incarceration for having been convicted of an offense or offenses that resulted in the death of two or more victims.

      (Added to NRS by 2015, 618)

     

Notes of Decisions
Cited in 25 cases (5 in the last 5 years), 2016–2025 · leading case: State of Iowa v. Christopher Ryan Lee Roby, 897 N.W.2d 127 (Iowa 2017).
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State of Iowa v. Christopher Ryan Lee Roby, 897 N.W.2d 127 (Iowa 2017). · cites it 2× “1–15); Nev. Rev. Stat. Ann. § 213.12135 (1)(a)–(b) (West, Westlaw current through 79th Reg.”
People v. Contreras, 411 P.3d 445 (Cal. 2018). “047 (1) [juvenile offenders sentenced to LWOP eligible for review of sentence after 25 years]; Nev. Rev. Stat. Ann. § 213.12135 [juvenile nonhomicide offenders eligible for parole after 15 years]; House Bill No.”
Carter, Bowie, McCullough v. State, 192 A.3d 695 (Md. 2018). “1402 (2)(d) (20 years); Nev. Rev. Stat. Ann. § 213.12135 (15 years); W.”
Bellon v. Williams (D. Nev. 2019). · cites it 12× “After Bellon’s 20 conviction, the Nevada legislature enacted NRS § 213.12135, which, as it applies to 21 Bellon, provides: 22 Notwithstanding any other provision of law .”
Hicks v. State, Bd. of Parole Comm'rs (Castillo) (Nev. 2016). · cites it 10× “" The Washoe County District Attorney argues that respondents have incorrectly read NRS 213.12135 as allowing for parole eligibility after 20 years even when the prisoner's sentence includes a consecutive sentence enhancement as is the case with the deadly weapon enhancement…”
Garcia (jonathan) v. State, 566 P.3d 1112 (Nev. 2025). · cites it 10× “SUPREME COURT OF NEVADA I047A 5 NRS 213.12135 does not limit the district court's sentencing authority, and resentencing is not necessary.”
Lani (David) v. State (Nev. 2019). · cites it 6× “3d 453 , 458-59 (2015) (holding that NRS 213.12135 applies to aggregate sentences for offenses committed when the offender is a juvenile) Lani argues that because NRS 213.”
Mitchell (Deangelo) v. State (Nev. 2017). · cites it 5× “Cadish, District Judge Deangelo Lamont Mitchell Attorney General/Carson City Clark County District Attorney Eighth District Court Clerk 1 We reject Mitchell's equal protection challenge to NRS 213.12135. We also note that NRS 213.”
Baker (Matthew) Vs. Warden (Nev. 2021). · cites it 5× “12135 (setting forth parole eligibility for juvenile offenders based on type of offenses), alleging that the offense date in the criminal record was incorrect and that the offenses were committed before he turned 18. The district court denied the petition, concluding that…”
Feazeal (Travis) Vs. State (Nev. 2019). · cites it 4× “48, 82 (2010) (holding that the Eighth Amendment "prohibits the imposition of a life without parole sentence on a juvenile 8NRS 213.12135 became effective on October 1, 2015, and applies retroactively to offenses "committed before, on or after October 1, 2015.”
Cobb v. Gittere (D. Nev. 2022). · cites it 4× “) 14 Moreover, the Nevada legislature enacted NRS § 213.12135 in 2015, which automatically 15 converted Cobb’s sentence to life with the possibility of parole after 20 years because he 16 was a juvenile at the time of the crime.”
Bellon (Robert) v. Warden (Nev. 2018). · cites it 3× “Even though Bellon is serving a sentence of life without the possibility of parole for a first-degree-murder conviction, NRS 213.12135 affords him parole eligibility because he was a juvenile at the time of the offense and the offense resulted in the death of only one victim.”
Show all 25 citing cases →
— Nev. Rev. Stat. § 213.12135(1) — 1 case
Garcia (jonathan) v. State, 566 P.3d 1112 (Nev. 2025). “SUPREME COURT OF NEVADA I047A 5 NRS 213.12135 does not limit the district court's sentencing authority, and resentencing is not necessary.”
— Nev. Rev. Stat. § 213.12135(1)(a) — 4 cases
Garcia (jonathan) v. State, 566 P.3d 1112 (Nev. 2025). “SUPREME COURT OF NEVADA I047A 5 NRS 213.12135 does not limit the district court's sentencing authority, and resentencing is not necessary.”
Mitchell (Deangelo) v. State (Nev. 2017). “Cadish, District Judge Deangelo Lamont Mitchell Attorney General/Carson City Clark County District Attorney Eighth District Court Clerk 1 We reject Mitchell's equal protection challenge to NRS 213.12135. We also note that NRS 213.”
Hicks v. State, Bd. of Parole Comm'rs (Castillo) (Nev. 2016). “" The Washoe County District Attorney argues that respondents have incorrectly read NRS 213.12135 as allowing for parole eligibility after 20 years even when the prisoner's sentence includes a consecutive sentence enhancement as is the case with the deadly weapon enhancement…”
Feazeal (Travis) Vs. State (Nev. 2019). “48, 82 (2010) (holding that the Eighth Amendment "prohibits the imposition of a life without parole sentence on a juvenile 8NRS 213.12135 became effective on October 1, 2015, and applies retroactively to offenses "committed before, on or after October 1, 2015.”
— Nev. Rev. Stat. § 213.12135(1)(b) — 8 cases
Hicks v. State, Bd. of Parole Comm'rs (Castillo) (Nev. 2016). “" The Washoe County District Attorney argues that respondents have incorrectly read NRS 213.12135 as allowing for parole eligibility after 20 years even when the prisoner's sentence includes a consecutive sentence enhancement as is the case with the deadly weapon enhancement…”
Bellon (Robert) v. Warden (Nev. 2018). “Even though Bellon is serving a sentence of life without the possibility of parole for a first-degree-murder conviction, NRS 213.12135 affords him parole eligibility because he was a juvenile at the time of the offense and the offense resulted in the death of only one victim.”
Bellon v. Williams (D. Nev. 2019). “After Bellon’s 20 conviction, the Nevada legislature enacted NRS § 213.12135, which, as it applies to 21 Bellon, provides: 22 Notwithstanding any other provision of law .”
Garcia (Angel) v. State (Nev. 2017).
Mitchell (Deangelo) v. State (Nev. 2017). “Cadish, District Judge Deangelo Lamont Mitchell Attorney General/Carson City Clark County District Attorney Eighth District Court Clerk 1 We reject Mitchell's equal protection challenge to NRS 213.12135. We also note that NRS 213.”
— Nev. Rev. Stat. § 213.12135(2) — 1 case
Garcia (Angel) v. State (Nev. 2017).
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