Trust-Company Applicants Must Prove Good Character by Clear and Convincing Evidence Under NRS 669.160

Case: HURRY v. STATE, DEP'T OF BUS. & INDUS. (CIVIL)

Court: Supreme Court of Nevada

Date: September 25, 2026

Disposition: District court judgment affirmed.

Introduction

John Hurry applied to the Nevada Financial Institutions Division (FID) for a license to operate a retail trust company. FID identified concerns arising from Hurry’s association with Alpine Securities and Scottsdale Capital, including investigations and enforcement proceedings conducted by the Financial Industry Regulatory Authority (FINRA). FID also questioned the proposed management team’s character and experience.

After Hurry declined to amend his application, FID denied it. An administrative law judge (ALJ) upheld the denial on two independent grounds: Hurry failed to establish the required good character by clear and convincing evidence, and the proposed directors collectively lacked sufficient experience under a preponderance-of-the-evidence standard.

The principal issues before the Nevada Supreme Court were whether the ALJ used the correct standard of proof, whether FID gave constitutionally adequate notice of the grounds for denial, and whether substantial evidence supported the agency’s decision.

Summary of the Opinion

  1. “Satisfactory proof” means clear and convincing evidence. NRS 669.160(1)(a)(1) requires an applicant to provide “satisfactory proof” that proposed directors, officers, and managers possess honesty, trustworthiness, integrity, and competence. Nevada precedent equates “satisfactory proof” with clear and convincing evidence.
  2. Different statutory provisions may carry different burdens of proof. The ALJ properly used the preponderance standard under NRS 669.085, which specifies no standard, while applying the higher clear-and-convincing standard under NRS 669.160.
  3. FID provided adequate procedural due process. Although FID’s denial order included grounds not stated in its initial deficiency letter, Hurry received notice of those grounds before the ALJ hearing and had an opportunity to contest them.
  4. Substantial evidence supported the character determination. FINRA findings concerning Hurry’s role in Alpine’s misconduct, combined with deficiencies in his disclosures and the absence of persuasive rebuttal evidence, adequately supported the ALJ’s conclusion.
  5. The later federal FINRA litigation did not undermine the agency record. The federal decision postdated the ALJ’s order, addressed only a likelihood of success on a constitutional claim, and expressly did not decide the merits.

Analysis

1. Statutory Framework and Standards of Proof

NRS 669.160(1)(a)(1) requires an applicant to prove that those who will direct or manage a trust company have a good reputation for honesty, trustworthiness, and integrity, as well as the competence necessary to safeguard the public. The statute places the burden on the applicant and requires “satisfactory proof.”

The court treated that phrase as a term with an established legal meaning. Because Nevada precedent equates “satisfactory proof” with clear and convincing evidence, the general administrative default of preponderance of the evidence did not apply.

By contrast, NRS 669.085 contains no express standard of proof. Under NRS 233B.121(9) and NRS 233B.125, the default preponderance standard therefore governed the ALJ’s assessment of the proposed directors’ experience. The use of two standards was not inconsistent; it reflected the different statutory language.

2. Precedents Cited

Statutory interpretation

Williams v. State, Dep't of Corr. established that statutory interpretation is reviewed de novo. The Supreme Court therefore independently determined the meaning of “satisfactory proof,” without deferring to the ALJ’s legal interpretation.

Kassebaum v. State, Dep't of Corr. supplied the rule that statutory interpretation begins with the statute’s plain text.

Savage v. Pierson supported the principle that words carrying a technical or specialized legal meaning are presumed to retain that meaning. This allowed the court to interpret “satisfactory proof” in light of established Nevada jurisprudence.

Meaning of “satisfactory proof”

In re Discipline of Drakulich directly equated “satisfactory proof” with clear and convincing evidence. It was central to the court’s interpretation of NRS 669.160.

Gilman v. Nev. State Bd. of Veterinary Med. Exam'rs likewise equated the two standards in an administrative setting. Hurry argued that Gilman was no longer valid, but the court rejected that contention.

Nassiri v. Chiropractic Physicians' Bd. disapproved Gilman only insofar as Gilman conflated a standard of proof with a standard of judicial review. It did not reject the conclusion that “satisfactory proof” means clear and convincing evidence.

The court also found the legislative history consistent with this interpretation. When the Legislature amended the statute involved in Gilman, it replaced “satisfactory proof” with “preponderance of the evidence.” That change indicated a deliberate lowering of the burden for those proceedings rather than a redefinition of “satisfactory proof.”

Procedural due process

Sw. Gas Corp. v. Pub. Utils. Comm'n of Nev. established de novo review for procedural due process claims.

Hernandez v. Bennett-Haron recognized that constitutional due process protections apply to agency action affecting protected interests.

Dutchess Bus. Servs., Inc. v. Nev. State Bd. of Pharmacy requires an agency to notify the affected party of the decisive issues and factual material so that the party can rebut them at a hearing.

Regency Air, LLC v. Dickson holds that when an agency changes or adds a theory during proceedings, the opposing party must receive an opportunity to present argument under that theory. Hurry received that opportunity because the additional grounds appeared in FID’s denial order and the later ALJ hearing was confined to those disclosed grounds.

Issue preservation

Khoury v. Seastrand supported the rule that a party may not raise new arguments for the first time in a reply brief.

Old Aztec Mine, Inc. v. Brown supported the court’s refusal to consider issues not timely raised below. Consequently, three additional due process theories asserted by Hurry were treated as forfeited.

Substantial-evidence review

Elizondo v. Hood Mach., Inc. provides that an agency’s factual findings will be overturned when they lack substantial evidence.

Law Offs. of Barry Levinson, P.C. v. Milko defines substantial evidence as evidence a reasonable person could regard as adequate to support the agency’s conclusion.

The federal FINRA litigation

Alpine Sec. Corp. v. Fin. Indus. Regul. Auth. concerned Alpine’s constitutional challenge to FINRA’s expulsion authority. The federal court found a likelihood of success on a nondelegation claim and temporarily prevented expulsion, but expressly stated that it was not resolving the merits.

The Nevada Supreme Court concluded that this federal ruling did not discredit FINRA’s underlying factual findings. It also postdated the ALJ’s decision and therefore fell outside the administrative record to which judicial review was confined under NRS 233B.135(1)(b).

3. Legal Reasoning

Character had to be proven affirmatively

The licensing scheme did not require FID to prove that Hurry lacked good character. Rather, Hurry bore the affirmative burden of demonstrating good character by clear and convincing evidence. His failure to carry that burden was independently sufficient to deny the license.

The FINRA evidence was relevant and substantial

The administrative record indicated that Hurry indirectly owned Alpine through trusts he managed and exercised influence over the company’s director. FINRA attributed important decisions leading to misconduct to Hurry, including policies associated with:

  • a monthly account fee increased from $100 annually to $5,000 monthly;
  • a difficult online account system and reduced customer access;
  • the use of customer funds to satisfy fees without authorization;
  • unfair prices and commissions;
  • unauthorized trading and a capital withdrawal; and
  • management practices inconsistent with the protection of customers.

The ALJ was entitled to credit those findings. The evidence directly concerned whether Hurry could be trusted to manage an institution holding fiduciary responsibilities toward the public.

Nondisclosure reinforced the character concerns

Hurry’s application asked whether he had been directly or indirectly connected with an organization subject to administrative or enforcement action. Although he answered “yes,” his explanation did not identify the FINRA proceedings involving Alpine and Scottsdale. The ALJ could reasonably regard that omission as further evidence bearing on honesty, candor, and trustworthiness.

Due process was measured across the proceedings as a whole

FID’s initial deficiency letter did not contain every ground later asserted. Nevertheless, the denial order identified the additional grounds before the ALJ hearing. Because Hurry could contest those matters at the hearing, the process supplied both notice and an opportunity to be heard. Due process did not require every eventual ground to appear in the earliest communication.

Standards of proof and review remained distinct

Clear and convincing evidence governed what Hurry had to prove before the ALJ. Substantial evidence governed the courts’ review of the ALJ’s factual determination. The reviewing court did not decide the character issue anew or reweigh the evidence; it asked whether a reasonable person could support the ALJ’s conclusion that Hurry failed to meet his elevated burden.

Potential Impact

  • Heightened scrutiny for trust-company applicants: Applicants under NRS 669.160 must present affirmative, persuasive evidence of honesty, integrity, trustworthiness, and competence.
  • Broader significance of “satisfactory proof”: Unless a statute indicates otherwise, Nevada agencies and courts may continue to treat this phrase as requiring clear and convincing evidence.
  • Agency reliance on regulatory findings: Licensing authorities may consider findings by FINRA and similar regulatory bodies when those findings bear on an applicant’s character or competence.
  • Flexible but fair agency notice: Agencies may add or refine grounds after an initial notice, provided the affected party receives meaningful notice and a genuine opportunity to respond before final adjudication.
  • Strict record and preservation rules: Parties seeking judicial review must timely present their arguments and generally cannot rely on evidence or decisions arising after the administrative record closes.

The opinion is also limited in important respects. The court did not decide whether the experience-based denial under NRS 669.085 was independently correct because the character determination alone sustained the result. Nor did it rely on every FINRA allegation involving Alpine or Scottsdale.

Complex Concepts Simplified

Preponderance of the evidence
Proof that a proposition is more likely true than not true.
Clear and convincing evidence
A higher civil burden requiring evidence that produces a firm belief in the proposition asserted. It is more demanding than preponderance but lower than proof beyond a reasonable doubt.
Substantial evidence
Enough relevant evidence that a reasonable person could accept it as supporting the agency’s conclusion.
Standard of proof
The degree of persuasion required before the original decision-maker, here the ALJ.
Standard of review
The level of scrutiny a reviewing court applies to the agency’s decision.
Procedural due process
The constitutional requirement that a person receive adequate notice and a meaningful opportunity to respond before the government makes a qualifying adverse decision.
Nondelegation doctrine
The principle that governmental power may not be transferred to another entity without constitutionally adequate limits and oversight.
Forfeiture
The loss of an argument because it was not raised at the proper time.

Conclusion

The Nevada Supreme Court confirmed that “satisfactory proof” under NRS 669.160 requires clear and convincing evidence. Because trust companies occupy positions of exceptional public confidence, an applicant must affirmatively establish the honesty, integrity, trustworthiness, and competence of those who will control the institution.

Hurry did not meet that burden. FINRA’s findings concerning his role in Alpine’s treatment of customer funds, his incomplete disclosures, and his failure to offer a persuasive rebuttal supplied substantial support for the denial. The additional grounds stated in FID’s denial order did not violate due process because Hurry received notice and an opportunity to contest them at the ALJ hearing. The decision therefore reinforces rigorous character review in Nevada financial licensing while distinguishing the burden before an agency from the standard applied on judicial review.