Nevada Revised Statutes

Nev. Rev. Stat. § 278.3195 (2026)

Governing body to adopt ordinance allowing appeal to governing body concerning certain decisions regarding use of land; required contents of ordinance; appeal of decision of governing body to district court

✓ current as of July 2026
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NRS 278.3195  Governing body to adopt ordinance allowing appeal to governing body concerning certain decisions regarding use of land; required contents of ordinance; appeal of decision of governing body to district court.

      1.  Except as otherwise provided in NRS 278.310, each governing body shall adopt an ordinance providing that any person who is aggrieved by a decision of:

      (a) The planning commission, if the governing body has created a planning commission pursuant to NRS 278.030;

      (b) The board of adjustment, if the governing body has created a board of adjustment pursuant to NRS 278.270;

      (c) A hearing examiner, if the governing body has appointed a hearing examiner pursuant to NRS 278.262; or

      (d) Any other person appointed or employed by the governing body who is authorized to make administrative decisions regarding the use of land,

Ê may appeal the decision to the governing body. In a county whose population is 700,000 or more, a person shall be deemed to be aggrieved under an ordinance adopted pursuant to this subsection if the person appeared, either in person, through an authorized representative or in writing, before a person or entity described in paragraphs (a) to (d), inclusive, on the matter which is the subject of the decision.

      2.  Except as otherwise provided in NRS 278.310, an ordinance adopted pursuant to subsection 1 must set forth, without limitation:

      (a) The period within which an appeal must be filed with the governing body.

      (b) The procedures pursuant to which the governing body will hear the appeal.

      (c) That the governing body may affirm, modify or reverse a decision.

      (d) The period within which the governing body must render its decision except that:

             (1) In a county whose population is 700,000 or more, that period must not exceed 45 days.

             (2) In a county whose population is less than 700,000, that period must not exceed 60 days.

      (e) That the decision of the governing body is a final decision for the purpose of judicial review.

      (f) That, in reviewing a decision, the governing body will be guided by the statement of purpose underlying the regulation of the improvement of land expressed in NRS 278.020.

      (g) That the governing body may charge the appellant a fee for the filing of an appeal.

      3.  In addition to the requirements set forth in subsection 2, in a county whose population is 700,000 or more, an ordinance adopted pursuant to subsection 1 must:

      (a) Set forth procedures for the consolidation of appeals; and

      (b) Prohibit the governing body from granting to an aggrieved person more than two continuances on the same matter, unless the governing body determines, upon good cause shown, that the granting of additional continuances is warranted.

      4.  Any person who:

      (a) Has appealed a decision to the governing body in accordance with an ordinance adopted pursuant to subsection 1; and

      (b) Is aggrieved by the decision of the governing body,

Ê may appeal that decision to the district court of the proper county by filing a petition for judicial review within 25 days after the date of filing of notice of the decision with the clerk or secretary of the governing body, as set forth in NRS 278.0235.

      5.  As used in this section, “person” includes the Armed Forces of the United States or an official component or representative thereof.

      (Added to NRS by 2001, 2803; A 2003, 1734; 2007, 354; 2011, 1193)

DIVISIONS OF LAND

Subdivision of Land: General Provisions

     

Notes of Decisions
Cited in 15 cases (6 in the last 5 years), 2006–2025 · leading case: Kay v. Nunez, 146 P.3d 801 (Nev. 2006).
Kay v. Nunez, 146 P.3d 801 (Nev. 2006). · cites it 19× “As the petition for judicial review was the proper mechanism, under NRS 278.3195, to invoke the district court’s jurisdiction to examine the administrative decision, Kay’s writ peti *1106 tion was inappropriate.”
City of North Las Vegas v. Eighth Jud. Dist. Court of the State of Nevada ex rel. Cnty. of Clark, 147 P.3d 1109 (Nev. 2006). · cites it 19× “” Planning commission decisions involving special use permits may be challenged in accordance with local ordinances adopted under NRS 278.3195. 17 NRS 278.3195 requires most local governing bodies to adopt an ordinance governing administrative appeals from land use decisions,…”
Mesagate Homeowners' Ass'n v. City of Fernley, 194 P.3d 1248 (Nev. 2008). · cites it 12× “” In our view, the approval of the building permit at issue in this case did not constitute a “final ac *1094 tion, decision or order’ ’ when considered in light of a second provision, NRS 278.3195. NRS 278.3195(1) requires a governing body to adopt an ordinance providing any…”
City of Reno v. Citizens for Cold Springs, 236 P.3d 10 (Nev. 2010). · cites it 2× “The court arrived at this conclusion based on the express language in NRS 278.3195(4), which sets forth that a person who administratively appeals a zoning decision under the applicable ordinance to the governing board and is aggrieved by the board’s decision may appeal by…”
Carrigan v. Comm'n on Ethics, 236 P.3d 616 (Nev. 2010). · cites it 2× “49504/49682/50251 (Order of Affirmance, July 21, 2009), where we held that the Lazy 8 vote represented a land use decision reviewable, if at all, by a petition for judicial review under NRS 278.3195(4). Although policy-setting land use planning ordinances qualify as legislative,…”
City of Henderson Vs. Dist. Ct. (solid State Props., Llc), 2021 NV 26 (Nev. 2021). · cites it 14× “Solid State cited to NRS 278.3195, which provides an aggrieved party the ability to appeal the land use decision of a governing body to the district court.”
Demartini v. City Of Reno (Nev. 2022). · cites it 8× “NRS 278.3195 only defines the term “aggrieved” for counties with populations over 700,000.”
Demartini v. City Of Reno (Nev. 2022). · cites it 8× “NRS 278.3195 only defines the term "aggrieved" for counties with populations over 700,000.”
Mcsweeney-Wilson v. Storey Cty. Comm'Rs (Nev. 2022). · cites it 6× “Under the plain language of NRS 278.3195, Wilson lacked standing to seek judicial review of the County Commissioners decision because she did not attend or participate in any of the planning commission or County Commission meetings considering Stericycle's application and she…”
Scenic Nevada, Inc. Vs. City Of Reno (Nev. 2021). · cites it 3× “860; NRS 278.3195. Nothing in the record provides any indication that Scenic Nevada availed itself of these remedies before seeking relief from the district court.”
Reno Real Est. Devel., LLC v. Scenic Nevada, Inc. c/w 87549, 141 Nev. Adv. Op. No. 48 (Nev. 2025). · cites it 3× “NRS 278.3195 provides a mechanism for private individuals to challenge land use decisions.”
Eldorado Hills, LLC v. Clark Cnty. Bd. of Commissioners (Nev. 2016). · cites it 2× “We disagree and conclude that Boulder City is a "person" pursuant to NRS 278.3195 and the Nevada Administrative Procedure Act.”
— Nev. Rev. Stat. § 278.3195(1) — 9 cases
Kay v. Nunez, 146 P.3d 801 (Nev. 2006). “As the petition for judicial review was the proper mechanism, under NRS 278.3195, to invoke the district court’s jurisdiction to examine the administrative decision, Kay’s writ peti *1106 tion was inappropriate.”
City of North Las Vegas v. Eighth Jud. Dist. Court of the State of Nevada ex rel. Cnty. of Clark, 147 P.3d 1109 (Nev. 2006). “” Planning commission decisions involving special use permits may be challenged in accordance with local ordinances adopted under NRS 278.3195. 17 NRS 278.3195 requires most local governing bodies to adopt an ordinance governing administrative appeals from land use decisions,…”
Mesagate Homeowners' Ass'n v. City of Fernley, 194 P.3d 1248 (Nev. 2008). “” In our view, the approval of the building permit at issue in this case did not constitute a “final ac *1094 tion, decision or order’ ’ when considered in light of a second provision, NRS 278.3195. NRS 278.3195(1) requires a governing body to adopt an ordinance providing any…”
Demartini v. City Of Reno (Nev. 2022). “NRS 278.3195 only defines the term “aggrieved” for counties with populations over 700,000.”
Demartini v. City Of Reno (Nev. 2022). “NRS 278.3195 only defines the term "aggrieved" for counties with populations over 700,000.”
— Nev. Rev. Stat. § 278.3195(1)(a) — 2 cases
Demartini v. City Of Reno (Nev. 2022). “NRS 278.3195 only defines the term “aggrieved” for counties with populations over 700,000.”
Demartini v. City Of Reno (Nev. 2022). “NRS 278.3195 only defines the term "aggrieved" for counties with populations over 700,000.”
— Nev. Rev. Stat. § 278.3195(3)(a) — 1 case
City of North Las Vegas v. Eighth Jud. Dist. Court of the State of Nevada ex rel. Cnty. of Clark, 147 P.3d 1109 (Nev. 2006). “” Planning commission decisions involving special use permits may be challenged in accordance with local ordinances adopted under NRS 278.3195. 17 NRS 278.3195 requires most local governing bodies to adopt an ordinance governing administrative appeals from land use decisions,…”
— Nev. Rev. Stat. § 278.3195(4) — 10 cases
Kay v. Nunez, 146 P.3d 801 (Nev. 2006). “As the petition for judicial review was the proper mechanism, under NRS 278.3195, to invoke the district court’s jurisdiction to examine the administrative decision, Kay’s writ peti *1106 tion was inappropriate.”
Mesagate Homeowners' Ass'n v. City of Fernley, 194 P.3d 1248 (Nev. 2008). “” In our view, the approval of the building permit at issue in this case did not constitute a “final ac *1094 tion, decision or order’ ’ when considered in light of a second provision, NRS 278.3195. NRS 278.3195(1) requires a governing body to adopt an ordinance providing any…”
City of Reno v. Citizens for Cold Springs, 236 P.3d 10 (Nev. 2010). “The court arrived at this conclusion based on the express language in NRS 278.3195(4), which sets forth that a person who administratively appeals a zoning decision under the applicable ordinance to the governing board and is aggrieved by the board’s decision may appeal by…”
Carrigan v. Comm'n on Ethics, 236 P.3d 616 (Nev. 2010). “49504/49682/50251 (Order of Affirmance, July 21, 2009), where we held that the Lazy 8 vote represented a land use decision reviewable, if at all, by a petition for judicial review under NRS 278.3195(4). Although policy-setting land use planning ordinances qualify as legislative,…”
City of Henderson Vs. Dist. Ct. (solid State Props., Llc), 2021 NV 26 (Nev. 2021). “Solid State cited to NRS 278.3195, which provides an aggrieved party the ability to appeal the land use decision of a governing body to the district court.”
— Nev. Rev. Stat. § 278.3195(l) — 1 case
City of North Las Vegas v. Eighth Jud. Dist. Court of the State of Nevada ex rel. Cnty. of Clark, 147 P.3d 1109 (Nev. 2006). “” Planning commission decisions involving special use permits may be challenged in accordance with local ordinances adopted under NRS 278.3195. 17 NRS 278.3195 requires most local governing bodies to adopt an ordinance governing administrative appeals from land use decisions,…”
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