The Court reviewed the procedure to renew a judgment under NRS 17.214 and considered whether a judgment creditor must strictly comply with NRS 17.214(3)’s certified mail method-of-notice requirement. The Court explains that NRS 17.214(3) requires a judgment creditor to notify a judgment debtor within three days of filing the affidavit to renew a judgment. Additionally, the Court reaffirmed Leven’s2 holding that a judgment creditor must comply with NRS 17.214(3) to renew a judgment and found that the procedural requirement of the certified mail method-of-notice necessitates strict compliance. Accordingly, the Nevada Supreme Court affirms the district court’s ruling that BMO did not strictly comply with NRS 17.214 and thus could not renew its judgment against the Whittemores.
Gordon, Michelle, "BMO Harris Bank, N.A. v. Whittemore, 139 Nev. Adv. Op. 31 (Sep. 14, 2023)" (2023). Nevada Supreme Court Summaries. 1594.