His health problems prompted an early resignation from the territorial bench and he practiced law for several years before his death at age 39.

[2] Nave then completed a law degree at Northwestern University in 1897 and was a member of the Delta Chi fraternity.

[2] In March 1899, Nave was appointed as the clerk for a committee created to overhaul the territorial legal code.

[2] President Theodore Roosevelt appointed Nave to replace Eugene A. Tucker as Associate Justice of the Arizona Territorial Supreme Court on November 8, 1905.

[8] Ford v. United States, 12 Arizona 23 (1908) was concerned with charges of conspiracy to commit adultery within a brothel.

[9] Among his more unusual cases were Duffield v. Ashurst, 12 Arizona 360 (1909) which dealt with Ralph H. Cameron's right to collect tolls for use of the Bright Angel Trail.

Nave found the court had no jurisdiction to determine which printing company would receive a contract from a county board of supervisors in Hammer v. Smith, 11 Arizona 420 (1908).

[13] Shortly thereafter, Nave's health took a significant downturn and he spent the summer of 1912 in Los Angeles trying to recover.