Nevada Revised Statutes
Nev. Rev. Stat. § 51.075 (2026)
General exception; other exceptions illustrative
✓ current as of July 2026
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NRS 51.075 General exception; other exceptions illustrative.
1. A statement is not excluded by the hearsay rule if its nature and the special circumstances under which it was made offer assurances of accuracy not likely to be enhanced by calling the declarant as a witness, even though the declarant is available.
2. The provisions of NRS 51.085 to 51.305, inclusive, are illustrative and not restrictive of the exception provided by this section.
(Added to NRS by 1971, 794)
Notes of Decisions
Cited in 26
cases (1 in the last 5 years), 1976–2021 · leading case: Collman v. State, 7 P.3d 426 (Nev. 2000).
Collman v. State, 7 P.3d 426 (Nev. 2000). “This court concluded that the trial court did not err by admitting the testimony and letter pursuant to NRS 51.075 because the radiologist was a disinterested witness with no motive to lie.”
Johnstone v. State, 548 P.2d 1362 (Nev. 1976). “Since it was inferable from the other evidence that both Theriault and Paulette participated in Carone murders, if the jury had been allowed to know that only two persons with a connection to room 1214 had been prowling near the Carone room on the evening of those murders, then…”
Guy v. State, 839 P.2d 578 (Nev. 1992). “Appellant concedes as much in his opening brief, but asserts that the statement was nevertheless admissible at trial under NRS 51.075, NRS 51.315, or NRS 51.345. [3] We disagree.”
Lytle v. State, 816 P.2d 1082 (Nev. 1991). “Indeed, if the State had sought to introduce hearsay testimony under NRS 51.075 (general exception based upon assurances of accuracy), I must assume that the reliability hearing required under NRS 51.”
City of Las Vegas v. Walsh, 91 P.3d 591 (Nev. 2004). “Alternatively, the City contends that this statement is admissible under the “catch all” hearsay exception — NRS 51.075. 3 Even if we accept the City’s interpretation that the nurse’s statement regarding not using alcohol solutions or alcohol-based swabs falls within the…”
Walker v. State, 944 P.2d 762 (Nev. 1997). “Walker argues that Riker’s change of plea statement and penalty hearing statement were admissible during the guilt phase under NRS 51.075, the general exception to the rule against hearsay, because they were made under special circumstances which offer assurances of accuracy.”
Ramirez v. State, 958 P.2d 724 (Nev. 1998). “Finkel's findings could not be introduced pursuant to the residual exception codified at NRS 51.075 [4] because the United States Supreme Court deemed Idaho's similar residual exception not to be firmly rooted for Confrontation Clause purposes and thus, evidence admitted…”
Jaeger v. State, 948 P.2d 1185 (Nev. 1997). “" NRS 51.075(1). We conclude that Alvarez's testimony was properly admitted because it was reliable and made under assurances of accuracy not likely to be enhanced by calling the people who actually performed the drug tests.”
Emmons v. State, 807 P.2d 718 (Nev. 1991). “However, NRS 51.075(1) provides that “[a] statement is not excluded by the hearsay rule if its nature and the special circumstances under which it was made offer assurances of accuracy not likely to be enhanced by calling the declarant as a witness, even though [the declarant]…”
State, Dep't of Motor Vehs. & Pub. Saf. v. Evans, 952 P.2d 958 (Nev. 1998). “Officer Lang testified he advised Evans of the implied consent law by reading it from a standardized form, and that Evans refused to take any test.”
Anaya v. State, 606 P.2d 156 (Nev. 1980). “075(1) provides, “A statement is not excluded by the hearsay rule if its nature and the special circumstances under which it was made offer assurances of accuracy not likely to be enhanced by calling the declarant as a witness, even though he is available.” Finally, our evidence…”
Clem v. State, 760 P.2d 103 (Nev. 1988). “See NRS 51.075. Further, Sexton later corroborated the statements in her testimony, which supports the declarant’s credibility.”
— Nev. Rev. Stat. § 51.075(1) — 12 cases
Collman v. State, 7 P.3d 426 (Nev. 2000). “This court concluded that the trial court did not err by admitting the testimony and letter pursuant to NRS 51.075 because the radiologist was a disinterested witness with no motive to lie.”
Jaeger v. State, 948 P.2d 1185 (Nev. 1997). “" NRS 51.075(1). We conclude that Alvarez's testimony was properly admitted because it was reliable and made under assurances of accuracy not likely to be enhanced by calling the people who actually performed the drug tests.”
City of Las Vegas v. Walsh, 91 P.3d 591 (Nev. 2004). “Alternatively, the City contends that this statement is admissible under the “catch all” hearsay exception — NRS 51.075. 3 Even if we accept the City’s interpretation that the nurse’s statement regarding not using alcohol solutions or alcohol-based swabs falls within the…”
Emmons v. State, 807 P.2d 718 (Nev. 1991). “However, NRS 51.075(1) provides that “[a] statement is not excluded by the hearsay rule if its nature and the special circumstances under which it was made offer assurances of accuracy not likely to be enhanced by calling the declarant as a witness, even though [the declarant]…”
Johnstone v. State, 548 P.2d 1362 (Nev. 1976). “Since it was inferable from the other evidence that both Theriault and Paulette participated in Carone murders, if the jury had been allowed to know that only two persons with a connection to room 1214 had been prowling near the Carone room on the evening of those murders, then…”
— Nev. Rev. Stat. § 51.075(2) — 1 case
Johnstone v. State, 548 P.2d 1362 (Nev. 1976). “Since it was inferable from the other evidence that both Theriault and Paulette participated in Carone murders, if the jury had been allowed to know that only two persons with a connection to room 1214 had been prowling near the Carone room on the evening of those murders, then…”
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