Document Type

Case Summary

Publication Date

10-2-2023

Case Synopsis

The Nevada Supreme Court affirmed the district court’s grant of summary judgment in a quiet title action disputing the ownership of real property. The Court held that, for the purposes of NRS 106.240, a Notice of Default is not sufficient to make a secured debt wholly due for the following reasons: (1) the plain language of the statute requires an interpretation of whether a debt is wholly due according to the original terms and any extensions, (2) state law requires a waiting period after a Notice of Default has been recorded before the debt can be accelerated, and accelerations of a debt must be clear and unequivocal, and (3) policy reasons behind the statute do not support its application to Notices of Default.

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