A massive hydrothermal belt interspersed with hot springs runs north and south along the eastern slope of the Sierra Nevada. Explorers and immigrants trekking across the Great Basin discovered hot springs in their travels and bathed in the water if it was not scalding. Heated mineral water was, and still is, believed to have curative properties. By the time communities were established near the western Great Basin's Carson Range in the 1850s, early settlers had claimed most of the hydrothermal springs in the region.

Because entrepreneurs developed several hot springs as long-standing resorts at an early date, there is competition to claim the title of first in business. "David Walley built the place as a health resort, the first in Nevada and one of the first in the West," wrote Basil Woon in the August 30, 1953, edition of Reno's Nevada State Journal. A long-standing belief espoused in numerous publications is that Walley's Hot Springs was Nevada's first hydrothermal health resort. According to David Walley's obituary published in the Carson Valley News for March 13, 1875, the spa opened a couple of miles south of Genoa in 1862. With just a tent for shelter, baths sold for fifty cents each. Walley erected the first bathhouse the following year, and in 1864 Walley's wife, Harriet, arrived from the East to help run Genoa Hot Springs resort. "From a mere rock pile has risen a magnificent hotel, bath-houses, stabling and ball room," the weekly News proclaimed.

The truth is that Abe Curry's Warm Springs near Carson City, and Steamboat Hot Springs south of the Truckee Meadows, operated as health resorts, with the requisite infrastructure, before David Walley purchased the hot springs in Carson Valley. Abraham Curry and his business associates purchased much of Eagle Valley in August 1858, established Carson City a month later, and included in their holdings was the warm springs where the State Prison on East Fifth Street is today. According to Curry's biographer, Doris Cerveri in her book With Curry's Compliments (1990), "Curry walled up the spring and covered it with a hand-hewn stone bathhouse, one hundred-sixty feet long by thirty-eight feet wide." There were six bath areas of various depths and temperatures. A hotel was completed in the summer of 1861. Beginning in October, the hotel and spa served as the site of Nevada's first territorial legislative session.

Like Curry's Warm Springs, Steamboat Hot Springs as a location for a health resort also predates Walley's Hot Springs. James Cameron and his associates "already have a hotel near the [Steamboat] springs," reported the Territorial Enterprise on March 10, 1860, "and Dr. J. Ellis intends to erect vapor baths there soon, as he believes that the escaped steam from the springs can be used with great advantage in the cure of diseases." In 1862, according to Myron Angel's History of Nevada (1881), Dr. Joseph Ellis built a thirty-four bed hospital with six or seven bathhouses.

Territorial Enterprise reporter and humorist Mark Twain partook of Steamboat Springs in August 1863. He wrote a colorful letter detailing his efforts to improve his health. Young Twain also spent time at Curry's Warm Springs and, it is claimed, at Walley's Hot Springs.

Numerous other geothermal springs have brought pleasure and/or therapeutic benefit to their patrons. For example, there are Grover's Hot Springs in Alpine County, California (John C. Fremont and Kit Carson visited the hot springs in January 1844); Carson Hot Springs (formerly Swift's and later Shaw's Hot Springs); and both Moana and Lawton Hot Springs in the Reno area, to name just a few.

The distinction of operating the first health resort business in Nevada actually goes to William P. Cosser. By 1854, according to Paolo Sioli's Historical Souvenir of El Dorado County, California (1883), Cosser—spelled Cozart in Sioli's publication—was the proprietor of a "bathhouse at the warm and cold springs, two miles south from the old Mormon Station." Cosser, a Scotsman who moved with his family to Carson Valley in 1852, ran a modest health spa at the site where David Walley would open his business in 1862. Walley clearly did not operate the area's first health resort; however, the location two miles south of Genoa was the site of Nevada's first hot springs resort thanks to William Cosser.