Some Place or Another: Nevada Supreme Court Expands Reach of Nevada’s Luring Statute

Enacted in 1967, Nevada’s “employment-luring” statute prohibits employers from inducing, influencing, persuading, or engaging prospective employees to “change from one place or another in this state” or to “bring workers of any class or calling into this state” by “false or deceptive representations, false advertising or false pretenses.” Such representations/pretenses relate to the (a) kind or character of work to be done; (b) amount and character of the compensation to be paid for the work; (c) sanitary or other conditions of employment; or (d) existence of a strike or other trouble between the employees and management. Nevada Revised Statutes (NRS) 613.010. The statute further provides that an employee can bring a claim under this statute if an employer “induce[d] the worker to change his or her place of employment, or place of abode . . . .”

Given this language, Nevada courts have routinely found that the phrase “change from one place to another in this state” required an employee to physically relocate from another state to Nevada, or at least, to change their place of residence before the statute applied. For example, federal courts in Nevada have required employees bringing a luring claim to demonstrate that they physically relocated their place of residence. See Severson v. Absolute Dental Grp., LLC, No. 2:22-cv-01916-GMN-VCF, 2023 WL 2772004 (D. Nev. Apr. 1, 2023); Turner v. Harvard MedTech of Nev., LLC, No. 2:22-cv-1264-JCM (BNW) (D. Nev. July 27, 2023). 

In Severson, the plaintiff’s claim under NRS 613.010 failed because, despite putting her Arizona house on the market in preparation for moving to Nevada, the plaintiff never actually moved to Nevada prior to her employment being terminated. The court held that because the plaintiff did not allege that “she physically relocated to Nevada, her claim under NRS 613.010 fails as a matter of law.”

Similarly, in Turner, the court found that the plaintiff, who was recruited and ultimately left one job for the recruited job, could not bring a claim under NRS 613.010 because he did not physically relocate to Nevada. The court found that while the plaintiff did change his place of employment, he did not change his “place of abode” as stated in the statute. Based on the Severson and Turner decisions, Nevada employers were able to achieve dismissal of a “luring” claim if the employee never actually moved their physical location for employment. 

However, on December 4, 2025, the Nevada Supreme Court substantially expanded the reach of this statute. In Field Effect Security, Inc. v. Eighth Judicial District Court, 141 Nev. Adv. Op. 63 (2025), the court held that the text and history of NRS 613.010 merely require employees to change their place of employment to satisfy the statute’s initial prong and do not require employees to relocate their place of residence. 

In this case, a former employee argued that the company lured him away from a competitor based on false promises about his role and compensation. The employee did not relocate his residence to accept the position with the company and lived at the same Las Vegas residence before, during, and after his employment. As did the defendants in Severson and Turner, the employer argued that the statute did not apply because it required an employee to have physically relocated their residence. The Nevada Supreme Court disagreed, finding that “changing a place of employment satisfies the requirements for a civil claim under NRS 613.010.” In so doing, the Nevada high court rejected the federal courts’ contrary positions. Therefore, to bring a claim under NRS 613.010, Nevada employees need only demonstrate that they changed their place of employment. 

Notably, the Nevada Supreme Court did not offer additional guidance on what conduct constitutes false or deceptive misrepresentations or false advertising about the employment to create liability. However, it is now clear that an employee need only demonstrate that they moved from one employer to another to satisfy the “change from one place to another” language in NRS 613.010.  

Given this decision, there will likely be an uptick in claims filed under NRS 613.010, and employers should be prepared to defend against them accordingly. Employers can take proactive steps to review their recruiting, interviewing, and offer‑making practices. Employers may also wish to revisit template offer letters, recruiting scripts, and onboarding communications to minimize the risk that candidates later claim they were “lured” by false or misleading statements. Accordingly, employers in Nevada should consult with experienced employment counsel to assess their current practices and develop a strategy that reduces exposure moving forward.