Nev. Rev. Stat. » NRS: CHAPTER 48 - ADMISSIBILITY GENERALLY
Nevada Revised Statutes

Nev. Rev. Stat. § 48.105 (2026)

Compromise; offers to compromise

✓ current as of July 2026
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NRS 48.105  Compromise; offers to compromise.

      1.  Evidence of:

      (a) Furnishing or offering or promising to furnish; or

      (b) Accepting or offering or promising to accept,

Ê a valuable consideration in compromising or attempting to compromise a claim which was disputed as to either validity or amount, is not admissible to prove liability for or invalidity of the claim or its amount. Evidence of conduct or statements made in compromise negotiations is likewise not admissible.

      2.  This section does not require exclusion when the evidence is offered for another purpose, such as proving bias or prejudice of a witness, negativing a contention of undue delay, or proving an effort to obstruct a criminal investigation or prosecution.

      (Added to NRS by 1971, 781)

     

Notes of Decisions
Cited in 17 cases (3 in the last 5 years), 1979–2025 · leading case: Davis v. Beling, 278 P.3d 501 (Nev. 2012).
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Davis v. Beling, 278 P.3d 501 (Nev. 2012). · cites it 17× “First, we are asked to construe NRS 48.105, which provides that evidence of offers of compromise must be excluded when introduced “to prove liability for or invalidity of the claim or its amount,” but also states that exclusion is not required “when the evidence is offered for…”
Morrison v. Beach City LLC, 991 P.2d 982 (Nev. 2000). · cites it 7× “Federal Rule of Evidence 408 (the federal analog of NRS 48.105), governing admissibility of offers to compromise, was developed to “encourage the resolution of problems through negotiation and settlement without the fear of having statements made during the negotiation process…”
Bigpond v. State, 270 P.3d 1244 (Nev. 2012). “5 See NRS 48.105(2) and NRS 48.135(2), which also use “such as” to introduce a nonexclusive list.”
Mallin v. Farmers Ins. Exch., 839 P.2d 105 (Nev. 1992). · cites it 2× “Ultimately, Egyed's estate entered into a settlement with these parties, without admitting applicability of these statutes, and this compromise was approved by the district court. Farmers' estoppel argument based upon these facts must fail, however, because compromises are not…”
Laman v. Nevada Real Est. Advisory Comm'n, 589 P.2d 166 (Nev. 1979). · cites it 3× “*58 Appellant contends that her written statement, dated April 15, 1976, and submitted to a Division investigator on April 16, 1976, should have been excluded under NRS 48.105, 6 as a statement “made in compromise negotiations”.”
McKenna v. State, 968 P.2d 739 (Nev. 1998). “Appellant’s conversation with police detectives Appellant contends that his conversation with Detective Samolovich was part of “compromise negotiations” and was therefore inadmissible pursuant to NRS 48.105(1) (evidence of conduct or statements made in compromise negotiations is…”
Folsom v. Woodburn, Wedge, Blakey & Jeppson, Chartered, 683 P.2d 9 (Nev. 1984). “025; NRS 48.105. Appellant contends the evidence should have been admitted to show that, even after deletion of paragraph 7, it was routine practice for the respondent law firm to pay terminating members more than the compensation determined under the five-year formula.”
Tmx, Inc. Vs. Volk C/W 75692 (Nev. 2019). · cites it 3× “Mallory argues his settlement offer was inadmissible under the plain language of NRS 48.105 because Volk used the settlement offer as evidence of Mallory's liability in her abuse of process claim and the amount of damages.”
Tmx, Inc. Vs. Volk C/W 75692 (Nev. 2019). · cites it 3× “Mallory argues his settlement offer was inadmissible under the plain language of NRS 48.105 because Volk used the settlement offer as evidence of Mallory's liability in her abuse of process claim and the amount of damages.”
Mirae Asset Sec. Co., Ltd. v. Ryze Renewables Holdings, LLC (D. Nev. 2025). · cites it 2× “5 10 Similarly, NRS § 48.105 limits the admissibility of offers to compromise and evidence of 11 conduct or statements made in compromise negotiations.”
Torres Vs. Nev. Direct Ins. Co. c/w 61640, 2015 NV 54 (Nev. 2015). · cites it 2× “One of NRS 48.105(1)'s "undisputed purposes. [is] to prevent evidence of settlement offers from `haunt[ing] a future legal proceeding.”
Rasmussen (Ivy) v. State C/W 68234 (Nev. 2018). “Demand letter Ballew and Rasmussen argue the district court erroneously allowed expert testimony regarding an offer of compromise to be admitted in violation of NRS 48.105(1)(a). However, the letter at issue was not an offer of compromise.”
Show all 17 citing cases →
— Nev. Rev. Stat. § 48.105(1) — 6 cases
Davis v. Beling, 278 P.3d 501 (Nev. 2012). “First, we are asked to construe NRS 48.105, which provides that evidence of offers of compromise must be excluded when introduced “to prove liability for or invalidity of the claim or its amount,” but also states that exclusion is not required “when the evidence is offered for…”
Morrison v. Beach City LLC, 991 P.2d 982 (Nev. 2000). “Federal Rule of Evidence 408 (the federal analog of NRS 48.105), governing admissibility of offers to compromise, was developed to “encourage the resolution of problems through negotiation and settlement without the fear of having statements made during the negotiation process…”
McKenna v. State, 968 P.2d 739 (Nev. 1998). “Appellant’s conversation with police detectives Appellant contends that his conversation with Detective Samolovich was part of “compromise negotiations” and was therefore inadmissible pursuant to NRS 48.105(1) (evidence of conduct or statements made in compromise negotiations is…”
Torres Vs. Nev. Direct Ins. Co. c/w 61640, 2015 NV 54 (Nev. 2015). “One of NRS 48.105(1)'s "undisputed purposes. [is] to prevent evidence of settlement offers from `haunt[ing] a future legal proceeding.”
Torres Vs. Nev. Direct Ins. Co. c/w 61640, 2015 NV 54 (Nev. 2015).
— Nev. Rev. Stat. § 48.105(1)(a) — 2 cases
Rasmussen (Ivy) v. State C/W 68234 (Nev. 2018). “Demand letter Ballew and Rasmussen argue the district court erroneously allowed expert testimony regarding an offer of compromise to be admitted in violation of NRS 48.105(1)(a). However, the letter at issue was not an offer of compromise.”
Rasmussen (Ivy) v. State C/W 68234 (Nev. 2018).
— Nev. Rev. Stat. § 48.105(2) — 3 cases
Davis v. Beling, 278 P.3d 501 (Nev. 2012). “First, we are asked to construe NRS 48.105, which provides that evidence of offers of compromise must be excluded when introduced “to prove liability for or invalidity of the claim or its amount,” but also states that exclusion is not required “when the evidence is offered for…”
Bigpond v. State, 270 P.3d 1244 (Nev. 2012). “5 See NRS 48.105(2) and NRS 48.135(2), which also use “such as” to introduce a nonexclusive list.”
Morrison v. Beach City LLC, 991 P.2d 982 (Nev. 2000). “Federal Rule of Evidence 408 (the federal analog of NRS 48.105), governing admissibility of offers to compromise, was developed to “encourage the resolution of problems through negotiation and settlement without the fear of having statements made during the negotiation process…”
— Nev. Rev. Stat. § 48.105(l)(b) — 1 case
Davis v. Beling, 278 P.3d 501 (Nev. 2012). “First, we are asked to construe NRS 48.105, which provides that evidence of offers of compromise must be excluded when introduced “to prove liability for or invalidity of the claim or its amount,” but also states that exclusion is not required “when the evidence is offered for…”
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