The Court determined that the test to determine if there was breach of the peace while undertaking self-help repossession considers: (1) repossession occurs at a reasonable time, (2) in a reasonable manner, and (3) that the objectives for self-help repossession are balanced to minimize violence in the act of and attempt to repossess. The Court also determined that the recovery from breach of peace in self-help repossession need not be brought only under NRS 104.9625. Recovery may be sought through a tort-based breach of peace claim.
Gonzales, Rachael T., "Droge v. AAAA Two Star Towing, Inc., 136 Nev. Adv. Op. 33 (Jun. 18, 2020)" (2020). Nevada Supreme Court Summaries. 1317.