The Court clarified two issues: (1) Sandy Valley Associates v. Sky Ranch Estates Owners Association’s and Horgan v. Felton’s effect on the law regarding the recovery of attorney fees as special damages; and (2) the extent to which Horgan retreated from Sandy Valley’s discussion about the grounds for recovering attorney fees as special damages.
Vitangeli, Allison, "Summary of Liu v. Christopher Homes, LLC, 130 Nev. Adv. Op. 17" (2014). Nevada Supreme Court Summaries. 8.