Nevada Revised Statutes

Nev. Rev. Stat. § 278.0235 (2026)

Actions against agency: Commencement; memorandum of points and authorities; reply

✓ current as of July 2026
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NRS 278.0235  Actions against agency: Commencement; memorandum of points and authorities; reply.

      1.  No action or proceeding may be commenced for the purpose of seeking judicial relief or review from or with respect to any final action, decision or order of any governing body, commission or board authorized by NRS 278.010 to 278.630, inclusive, unless the action or proceeding is commenced within 25 days after the date of filing of notice of the final action, decision or order with the clerk or secretary of the governing body, commission or board.

      2.  A petitioner or cross-petitioner who is seeking judicial review must serve and file a memorandum of points and authorities within 40 days after an action is commenced.

      3.  The respondent or cross-petitioners shall serve and file a reply memorandum of points and authorities within 30 days after the service of the memorandum of points and authorities.

      4.  The petition or cross-petitioner may serve and file a reply memorandum of points and authorities within 30 days after service of the reply memorandum.

      5.  Within 7 days after the expiration of the time within which the petitioner is required to reply, any party may request a hearing. Unless a request for hearing has been filed, the matter shall be deemed submitted.

      6.  All memoranda of points and authorities filed in proceedings involving petitions for judicial review must be in the form provided for appellate briefs in Rule 28 of the Nevada Rules of Appellate Procedure.

      7.  The court, for good cause, may extend the times allowed in this section for filing memoranda.

      (Added to NRS by 1971, 1264; A 1991, 48; 2013, 3217; 2015, 314; 2017, 2045; 2019, 969, 1295; 2021, 1443, 1527; 2025, 1077, 2377)

     

Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1984–2021 · leading case: Cnty. of Clark v. Doumani, 952 P.2d 13 (Nev. 1998).
Cnty. of Clark v. Doumani, 952 P.2d 13 (Nev. 1998). · cites it 11× “On January 20, 1994, appellants filed a motion to dismiss the complaint and petition for a writ, contending that respondents’ action was barred by the twenty-five day statute of limitations set forth in NRS 278.0235. Appellants asserted that the Board’s final decision was made…”
Mesagate Homeowners' Ass'n v. City of Fernley, 194 P.3d 1248 (Nev. 2008). · cites it 7× “Under NRS 278.0235, parties are permitted to challenge in district court “any final action, decision or order of any governing body, commission or board.”
Vari-Build, Inc. v. City of Reno, 596 F. Supp. 673 (D. Nev. 1984). · cites it 2× “NRS 278.0235. Defendants contend that planning and zoning procedures constitute the basis for Plaintiff’s Complaint herein, so that the statute applies.”
Carson City v. Capital City Ent., Inc., 49 P.3d 632 (Nev. 2002). “We note only that NRS 278.0235 provides a twenty-five-day limitations period for actions “commenced for the purpose of seeking judicial relief or review from or with respect to any final action, decision or order of any governing body, commission or board authorized by NRS 278.”
City of Reno v. Harris, 895 P.2d 663 (Nev. 1995). “On June 18, 1992, respondent Harris, the owner of the property located at One Elm Court, adjacent to Hawkins House, filed an “Application for Writ of Mandamus, Petition for Review (NRS 278.0235) or in the Alternative, Complaint for Declaratory Relief’ (petition) in the district…”
Fernhoff v. Tahoe Reg'l Plan. Agency, 622 F. Supp. 121 (D. Nev. 1985). “The 25-day limita *124 tion provided in NRS 278.0235 is limited to actions against the agency or governing body for relief from its zoning final actions.”
Helms v. State, Div. of Env't Prot., 849 P.2d 279 (Nev. 1993). “NRS 278.0235. NDEP was entitled to presume that the County’s approval was valid.”
City of Henderson Vs. Dist. Ct. (solid State Props., Llc), 2021 NV 26 (Nev. 2021). · cites it 4× “See NRS 278.0235 (setting 25-day time limit to "commence [ ]" an action or proceeding for judicial review); NRCP 3 advisory committee's note to 2019 amendment ("As used in these rules, 'complaint includes a petition or other document that initiates a civil action.”
Job's Peak Ranch v. Douglas Co. (Nev. 2015). · cites it 4× “The district court incorrectly dismissed the Association's remaining claims as untimely under NRS 278.0235 and NRS 11.190 NRS 278.0235 The district court broadly concluded that the Association's challenges to the County's adoptions of the Development Agreement, its amendments,…”
Lbt, Llc v. Sky Vista Assocs. C/W 60747 (Nev. 2013). · cites it 2× “In fact, they appeared numerous times to discuss and challenge the tentative map.”
Lbt, Llc v. Sky Vista Assocs. C/W 60747 (Nev. 2013). · cites it 2× “In fact, they appeared numerous times to discuss and challenge the tentative map.”
Scenic Nevada, Inc. Vs. City Of Reno (Nev. 2021). “2d 13, 16 (1998) (explaining that 'filing of notice of the final action under NRS 278.0235 is accomplished when someone or some entity provides separate, written notice of the final action to the secretary or clerk of the governing body, commission or board"), superseded by…”
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