Fredianelli v. MartinezAnnotate this Case
Nev. Rev. Stat. 18.015, which provides for the enforcement of liens for attorney fees, as amended in 2013, provides for the enforcement of a retaining lien for attorney fees.
Respondent represented Appellant in a paternity action. Respondent later filed and served a notice of a retaining lien against Appellant for $13,701 for unpaid legal fees. Respondent filed a motion asking the district court to adjudicate the rights of counsel, for enforcement of attorney’s lien, and for a judgment for attorney fees. Appellant argued that Respondent was asserting a charging lien, not a retaining lien, and that the purported charging lien failed as a matter of law. The district court granted Respondent’s motion. The Supreme Court affirmed, holding (1) the plain language of section 18.015 unambiguously permits an attorney to enforce a retaining lien; and (2) the district court did not err by enforcing Respondent’s valid retaining lien against Appellant under section 18.015.