Gumm v. Mainor

OPINION

This appeal from a post-judgment order provides us with an opportunity to clarify what constitutes a special order made after final judgment, which is substantively appealable under NRAP 3A(b)(2). We have generally held that a post-judgment order, to be appealable, must affect the rights of the parties growing out of the final judgment, but this standard has proved inadequate. Here, for example, the order does not technically affect the rights of the “parties” growing out of the final judgment, but only the rights of the plaintiff, his trial attorneys and various lienholders to receive…