Nevada family-law case summaries

Egan Walker and Laura Latimer divorced in 2002 after 13 years of marriage. During the marriage, Walker had worked as a deputy district attorney and earned about 8.54 years of credits in Nevada's Public Employees' Retirement System (PERS). As part of the divorce, the couple signed a marital settlement agreement that gave Latimer half of Walker's PERS retirement benefits accrued through June 1, 2001. To secure her share, the agreement called for a "qualified domestic relations order" (QDRO) - a court order recognized by retirement plans that directs how benefits are split. The QDRO required Walker to choose "Option 2" at retirement, which is a payment plan where the retiree gets a smaller monthly check during life so that, after death, a designated beneficiary continues receiving the same amount for life. After the divorce, Walker remarried, then later returned to public service as a court master and ultimately as a district court judge. When he became a judge, he had a one-time choice to keep his retirement benefits in PERS or move them into the Judicial Retirement System (JRS). He chose JRS and named his current wife as his beneficiary. Years later, when planning for retirement, Walker discovered that PERS and JRS had historically allowed only one person to be named as an Option 2 beneficiary. That created a problem: Latimer was contractually entitled to be an Option 2 beneficiary for her share, but Walker also wanted his current wife to be an Option 2 beneficiary for the rest. Walker asked the district court to sort it out. The district court agreed Walker could name both his ex-wife and current wife as Option 2 beneficiaries, but it also said Latimer was entitled only to 4.25 years of PERS credits and got nothing from the JRS account. The Nevada Supreme Court agreed with the district court that the relevant Nevada statute does not actually prohibit naming more than one Option 2 beneficiary. The court read the statute alongside other Nevada laws protecting a former spouse's interest in retirement benefits, and concluded that allowing two Option 2 beneficiaries best honors what the parties bargained for in the divorce: Latimer keeps her contracted-for share, and the current wife receives the rest. The court was not persuaded by PERS's arguments that federal tax law or actuarial complexity required a single-beneficiary rule. But the Supreme Court disagreed with the part of the order that gave Latimer credits in a PERS account that no longer exists. Because Walker had moved his PERS service credits into JRS, his old PERS account was closed, so awarding Latimer 4.25 years of credits in that closed account was, in the court's words, awarding her "a portion of nothing." The court held that when an ex-spouse has a protected interest in PERS retirement benefits and the member then transfers those benefits to JRS, the ex-spouse's interest follows the money into JRS. The case was sent back to the district court to fix that part of the order.

Richard and Eleni Kilgore married in 1992, both worked for Clark County (Richard as a marshal, Eleni as a teacher), and both earned retirement benefits through Nevada's PERS system. They divorced in 2013. The decree said how each spouse's PERS benefits would be split when the time came, but it did not address vacation pay or sick pay either spouse had built up during the marriage. In 2015, Eleni asked the district court to make Richard start paying her share of his PERS benefits, because Richard had reached the age and years-of-service combination that made him eligible to retire (he became eligible in 2011, when he turned 50, after more than 20 years as a marshal). She also asked for half of the vacation and sick pay Richard had accumulated during the marriage. Richard wanted to keep working to maximize his pension and argued he should not have to pay Eleni anything until he actually retires. The district court agreed that Eleni was entitled to her community-property share dating back to her March 2015 motion. It calculated that, had Richard retired, Eleni would have received $2,455 per month from PERS. Adding up the period from March 2015 to early 2017, the court found Richard owed Eleni $56,575.76 and reduced that to a judgment Eleni could collect by lawful means. But after looking closely at Richard's finances - his child-support obligation, basic living expenses, and what garnishment law would allow - the court ordered Richard to pay only $350 per month toward that judgment, rather than the full $2,455. The court also ordered Richard to pay Eleni half of the vacation and sick pay he had accrued during the marriage (after taxes). Both sides appealed. Richard argued the court should not have ordered any pre-retirement payment. Eleni argued she should have received the full $2,455 per month. Richard also argued vacation and sick pay are not community property and that it was too late to raise them. The Nevada Supreme Court affirmed everything. On the pension question, the court explained that under its prior decision in Gemma v. Gemma, a non-employee spouse can ask for her share of pension benefits once the employee spouse is first eligible to retire, even if he keeps working. But the Legislature later passed NRS 125.155, which gives the district court discretion to deny - or, the Supreme Court reasoned, reduce - such pre-retirement payments. The district court here used that discretion fairly: it preserved Eleni's full community-property interest by entering a judgment for the full amount owed, while letting Richard pay it down at $350 per month given his finances. On the vacation and sick pay, the court explained that a 2015 statute, NRS 125.150(3), lets either spouse come back within three years of discovering a mistakenly omitted asset and ask the court to divide it. Eleni did so within that window. The court held that vacation and sick pay earned during the marriage are a form of deferred compensation and therefore community property, even though they may be cashed out later.

Howard and Kristin Henson divorced in 1995. Their decree divided Howard's state pension (PERS) equally, using the 'time rule' and 'wait and see' approach from Gemma and Fondi. Years later, in 1999, a qualified domestic relations order (QDRO) was entered - at Kristin's request and without notice to Howard - that not only gave Kristin her share of the pension but also named her as Howard's survivor beneficiary, which prevented Howard from naming his new wife. In 2011 Howard asked the court to fix the QDRO. Kristin, in turn, asked to be paid the pension amounts she claimed she should have been receiving since Howard became eligible to retire in 2003. The Nevada Supreme Court, sitting en banc, ruled for Howard on both points. First, unless a divorce decree specifically says so, dividing a community-property interest in a pension does not also give the nonemployee spouse survivor benefits. The decree here divided only 'the pension' and did not award survivor benefits, so the QDRO wrongly made Kristin the survivor beneficiary; the amended QDRO (paying Kristin as if the unmodified benefit, so Howard could name another survivor without reducing her share) correctly carried out the decree. Second, when the employee spouse is eligible to retire but has not retired, the nonemployee spouse must file a motion in court asking to start receiving payments before any obligation to pay arises. Because Kristin never filed such a motion, Howard owed nothing for the years since 2003.

Roland and Maryann Shelton divorced after Roland's Navy career. Their divorce agreement, incorporated into the decree, split Roland's military retirement pay and gave Maryann $577 per month 'until her demise.' At the time, Roland was rated ten percent disabled and received a small disability payment. Roland made the required payments for two years. Then the Department of Veterans Affairs increased Roland's disability rating to 100 percent. Federal law lets a veteran waive military retirement pay in exchange for tax-free disability pay, and Roland did exactly that - waiving all his retirement pay for disability pay. He then stopped paying Maryann, arguing that federal law prohibits treating a veteran's disability pay as community property, so Maryann was entitled to nothing. The district court reluctantly agreed with Roland, relying on a U.S. Supreme Court decision (Mansell) that says states cannot divide military disability pay as community property. But it also felt the result was deeply unfair to Maryann. The Nevada Supreme Court reversed. It agreed that states cannot treat disability pay itself as community property, but it held that state contract law is a different matter and is not preempted by federal law. Roland had a contractual obligation - agreed to in the divorce decree - to pay Maryann $577 per month. He could not escape that obligation simply by unilaterally choosing to convert his retirement pay into disability pay. The court found the agreement, though ambiguous, was best read as requiring Roland to pay a fixed $577 monthly, which he had ratified by paying it for two years. Roland had to satisfy his contractual obligation from his other assets, and even his disability pay could be used voluntarily to do so. The court sent the case back for further proceedings.

Roberta and Gerhard Wolff married in 1982. Gerhard had worked for the Nevada Highway Patrol since 1972 and was in the state retirement system (PERS). They settled everything in their 1994 divorce except how to handle Gerhard's pension. The community had a 54% interest in it, worth about $1,155 a month. Because Gerhard kept working past his retirement eligibility date, the trial court did several things the Nevada Supreme Court found improper. First, it labeled Roberta's share of the pension as 'limited temporary spousal support' of $450 a month. The Court held this was wrong: a pension share is community property, which cannot be modified later, while spousal support can be reduced or ended on remarriage, death, or changed circumstances. Second, the trial court cut Roberta's monthly amount from about $578 to $450 without adequate explanation, violating the rule that community property is divided equally. Third, it wrongly ordered Gerhard to buy life insurance for Roberta's benefit, an unequal burden, especially since PERS already provides survivor protections. The Court upheld two rulings. Roberta's estate is entitled to her pension share if she dies before Gerhard, because at divorce the community interest becomes each spouse's separate property. And the trial court correctly treated each spouse's Social Security as their own separate property - but it erred by 'considering' Roberta's Social Security to reduce her PERS share, which is an improper offset.

Christopher Seaton filed an appeal on his own, without a lawyer, challenging a decision from a family court judge in Clark County about child custody. When someone appeals, the appellate court requires them to complete several procedural steps, such as requesting transcripts of the earlier proceedings and filing written arguments (called briefs) by set deadlines. On June 29, 2026, the court sent Seaton a notice telling him what he needed to file and when: a transcript request form (or a document stating no transcript was needed) within 14 days, a docketing statement within 21 days, and an opening brief within 60 days. When Seaton did not file the transcript form and docketing statement, the court gave him a second chance on August 3, 2026, ordering him to file those documents within 14 days and warning him that if he did not, his appeal could be dismissed. According to the court, Seaton never filed those documents. He also did not file his opening brief, which was due August 28, 2026, and he did not otherwise communicate with the court. Because it appeared to the court that Seaton had abandoned his appeal, the court dismissed it. This means the appeal ended without the court ever deciding whether the underlying custody decision was right or wrong.

This case involves a custody dispute between two divorced parents, Burke Hall and Vanessa Loftis, who had three children together. Their youngest child died in a tragic accident, and the parents divorced shortly after. In the divorce decree, the district court gave Loftis sole legal custody (the authority to make major decisions about the children) and primary physical custody (the children live mostly with her) of the two remaining children, S.H. (born 2009) and I.H. (born 2010). An earlier appeal affirmed that decree. Over time, with Loftis's consent, Hall began having weekend parenting time. In January 2024, Hall asked the court for joint legal and physical custody. He alleged that Loftis medically neglected the children and that her husband, Nathan Pressley, is a convicted felon. The court ordered the children interviewed at the Family Mediation Center, adopted the parents' informal parenting arrangement as a temporary order, increased Hall's child support based on his new full-time job, and scheduled an evidentiary hearing. Before that hearing, two incidents occurred involving Hall's household and S.H., who is on the autism spectrum. In one, Hall's wife Laura threw S.H.'s backpack (containing his laptop) off a second-floor landing after a dispute; she said S.H. pushed her. In the second, Hall said S.H. kicked him when Hall tried to take away a laptop; S.H. said Hall took the laptop and hit him on the head with it. S.H. was arrested after the second incident and placed in a specialized court program for autistic youth. Loftis asked the court to reduce Hall's visitation with S.H. and to be reimbursed for the laptop. The court reduced Hall's parenting time with S.H. to a short Friday window and ordered the laptop returned. Rather than proceed to a formal evidentiary hearing, the parties agreed to use the Informal Family Trial Court (IFTC) program. Before agreeing, both parties were told that the judge would question witnesses and that neither party could object during testimony. Both signed a form agreeing to those procedures and waiving the rules of evidence. At the informal trial, Hall testified about his concerns with Loftis's parenting and spent much of his time discussing Pressley's decades-old criminal convictions. He said he did not believe helping the children with homework was his responsibility because that was "a mother's job," and claimed Loftis suffered from "Munchausen syndrome." Loftis's employer, who ran an autism therapy facility both boys attended, testified that S.H. was not aggressive. Laura testified about the backpack incident and admitted she had refused to return the replacement laptop, claiming the court had no jurisdiction over her. Loftis testified about her efforts to obtain the children's autism diagnoses and therapy, and said she opposed joint legal custody because she feared Hall would undo that work since he disagreed with the diagnoses. The district court found that circumstances had changed (because the parties had informally modified their prior schedule) but denied joint custody based on its findings about the children's best interests. It kept Loftis's sole legal and primary physical custody, gave Hall weekend time with I.H. and a short Friday window with S.H. (with S.H. allowed to extend it at his own discretion), and imputed income to Hall for child support after finding his claim that he could not work was not credible. The court denied Hall's motion for reconsideration. On appeal, the Court of Appeals affirmed. It concluded Hall had voluntarily agreed to the informal trial procedures and therefore could not complain about them. It found the court's custody and child support findings were supported by substantial evidence, and emphasized that appellate courts do not reweigh evidence or reassess witness credibility.

Myisha and Ester Gray were married and share one child, born in 2017. After Myisha filed for divorce, the parties eventually agreed to share joint physical and legal custody, and the district court entered a divorce decree in 2022 adopting that agreement. The decree contained an "event" provision that let Myisha take the child to weekend events with seven days' notice, unless Ester already had plans with the child. The decree did not define "event." Ester later filed two motions to change the arrangement to give her primary physical custody. Her first motion, filed in November 2023, described a phone call from Myisha's girlfriend Rochelle reporting a domestic dispute in the child's presence (the "phone call incident"). The court declined to modify custody at that time, finding the parents had worked together in a stressful moment to keep the child's interests first. Ester's second motion, filed in November 2024, described a September 28, 2024 incident (the "soccer game incident") in which, according to Ester, Myisha pushed and hit her to separate her from the child, then grabbed the child by the arm and forced him into a vehicle as he screamed and cried. Myisha had been arrested for domestic violence in connection with that incident. Ester also said Myisha repeatedly used the "event" provision to take the child without her consent. The district court found a substantial change in circumstances based on the soccer game incident and gave Ester temporary primary physical custody. After an evidentiary hearing where both parents testified, the district court granted Ester primary physical custody. It found that Myisha had committed domestic violence during the soccer game incident and had used the "event" provision to interfere with Ester's parenting time. The court reviewed the statutory best-interest factors, found by clear and convincing evidence that Myisha's conduct amounted to domestic violence (triggering a legal presumption against her having joint or sole custody), and found Myisha's testimony not credible - especially her denial of the soccer game events. The court gave Myisha parenting time each week and on the first weekend of each month, ended the "event" provision, and later awarded Ester $20,000 in attorney fees (reduced from the $46,989.25 requested, in light of the income difference between the parties). On appeal, the Court of Appeals rejected each of Myisha's arguments. On the domestic violence history, the court found the record showed the district court did not use the older incidents (the gun incident and the phone call incident) to establish a "substantial change in circumstances"; instead it used them only in weighing the child's best interest, which is permitted. On the recorded phone call, the court held Myisha had objected below only on the ground that the call was recorded without consent, so her new hearsay and foundation arguments were forfeited and did not amount to plain error. On the claim that the court acted arbitrarily by revisiting the call, the court explained that credibility and weighing of evidence are left to the trial court, which used the call as one part of its overall credibility and best-interest analysis. On whether pulling the child's arm was domestic violence, the court said it did not need to decide that question because Myisha did not dispute that she committed domestic violence against Ester during the same incident, making any error harmless. On the rebuttal-evidence argument, the court held the findings were supported by substantial evidence and it would not reweigh credibility. Finally, the court upheld the fee award as within the district court's discretion.

This case involves a dispute over custody of a minor child between Vanessa R. Lovett and William Christensen. Lovett had appealed a district court order that modified child custody. While the appeal was pending, she asked the Court of Appeals to send the matter back to the district court temporarily - a step called a "remand" - so that the lower court could enter a new, permanent custody order. According to a district court order dated July 31, 2026, which Lovett attached to her motion, the two parties had reached an agreement on the record: Lovett would have sole legal and physical custody of the child, and Christensen would have no parenting time. The order stated the parties intended this arrangement to be permanent. Based on that agreement, the district court temporarily granted Lovett sole legal and physical custody and encouraged her to seek a remand from the appellate court so a permanent order could be entered. Christensen did not oppose Lovett's request. The Court of Appeals reviewed her unopposed motion and the district court's order and decided that sending the case back to the district court was warranted, so the lower court could enter a new permanent custody order. Lovett had asked that the remand be limited, saying she was not giving up her other arguments on appeal. The court instead concluded that dismissing the appeal was appropriate. The court added a note explaining that its order does not prevent Lovett from appealing the order the district court enters after remand, as long as she is harmed by that order and it is otherwise something that can be appealed.

Madison Buchanan and Corey Brewer were never married but had a child together, A.B., born in June 2020 in Las Vegas. After their romantic relationship ended in July 2022, they informally shared joint legal and physical custody of A.B. without a court order. Circumstances changed when Madison's now-husband accepted a job in Reno in June 2024 to be closer to his mother, who had been diagnosed with cancer. Madison then accepted her own job in Reno with an earlier start date, moving up her planned relocation to the end of October 2024. In response, Corey filed an amended complaint seeking joint legal and physical custody. Madison asked the court to set a temporary custody schedule and to allow her to relocate with A.B. to Reno. The parties went through mediation and agreed on some matters — they agreed to share joint legal custody and worked out schedules for holidays, vacations, and school breaks. But they could not agree on physical custody and relocation, so the district court held a trial where both parents testified. The testimony covered how they had shared custody, Corey's past drug use and his recovery efforts, the family support networks in both Las Vegas and Reno, Madison's better-paying Reno job and belief that Reno had better schools, and Madison's pregnancy and the chance for A.B. to spend more time with siblings. The district court decided that both parents were essentially equal when it came to what was best for A.B. Because the parent who wants to move must prove that moving is in the child's best interest, and because the court found the best-interest factors were evenly balanced (a "tie"), Madison did not carry that burden. The court denied her request to move and gave Corey primary physical custody. On appeal, the Court of Appeals reviewed the decision under an "abuse of discretion" standard — meaning it would not overturn the district court simply because it might have decided differently, but only if the decision lacked support in the evidence or was clearly wrong. The appeals court explained that because there was no prior permanent custody order in this case, the relocation statute the district court cited did not technically govern, but the district court was permitted to use that framework as a guide. The court found that the district court had properly considered whether Madison had a good reason to move (it found she did), and then weighed the child's best interest using the statutory best-interest factors. Because the district court's findings were supported by substantial evidence, and because the appeals court is not allowed to re-weigh the evidence itself, it affirmed the district court's decision.

Norma and Raymond Newcomb married in 1993 and divorced in 2020 through a stipulated decree - a divorce agreement the parties negotiated and the court approved. The decree treated their Henderson, Nevada home as community property (property belonging jointly to both spouses), gave Norma some lump-sum alimony plus an extra $15,000 "off the top" when the home sold, and split the remaining sale proceeds evenly. The decree also said Norma would list the home for sale herself (to save on realtor fees) and would move out, after which Raymond would have exclusive possession, with Raymond agreeing to cooperate with listing and showing the home. Things did not go smoothly. Raymond changed the locks on the home in August 2020. Norma said this locked her out and prevented her from preparing and listing the home, and that Raymond would not cooperate with a realtor she tried to bring in. Raymond said Norma had moved out of state and never genuinely tried to sell the home. The home was not sold until 2023, after Raymond went to court. In 2023, Raymond asked the court to find that Norma had violated the decree by not listing the home, and he argued that the resulting delay cost him money in mortgage payments that should be taken out of Norma's share of the sale proceeds. Norma responded that Raymond should be held in contempt and should bear the mortgage payments himself, because he was the one in exclusive possession and had locked her out. After a two-day evidentiary hearing spread over several months, the home sold for roughly $575,000. The district court found that it was not possible for Norma to list the home because she had been locked out, and that requiring her to list it would have been "an act of futility and impossibility." The court also noted that the community actually benefited from the delayed sale, because the home's value rose by about $180,000. Even so, the court ordered - without explaining why or citing any legal authority - that $26,929.37 in mortgage principal be deducted from Norma's share of the proceeds and given to Raymond. The Court of Appeals focused on that unexplained deduction. It observed that although the district court made detailed findings about why Norma could not list the home, it made no findings and gave no legal reasoning for making Norma responsible for the entire mortgage principal amount. The appellate court found this especially notable because the original reason Raymond asked for repayment was Norma's supposed deliberate delay - a delay the district court itself had found was actually impossible because of Raymond's actions. Because the order lacked the findings and legal explanation needed for the appellate court to review it, the Court of Appeals reversed the part of the order dealing with the mortgage principal payments, affirmed everything else in the challenged order, and sent the case back to the district court with instructions to explain the legal basis for its ruling on the mortgage principal payments.

Robert and Joanna Ronchi began dating in 2004. The day before their 2008 wedding in Pennsylvania, they signed a premarital agreement - a contract made before marriage that decides how property will be divided if the couple later divorces. The agreement said it would be governed by Pennsylvania law, listed each person's separate property (including Robert's interest in his business, Element 115, and his retirement accounts), and included provisions in which each spouse gave up any claim to property held in the other spouse's sole name. Joanna, a Polish citizen, was 19 weeks pregnant when she signed. The couple married the next day and moved to Nevada in 2010. In 2015, Robert bought a house, titled only in his name, that became the family home. Joanna filed for divorce in 2022. After hearings, the district court ruled the premarital agreement was valid. It then divided the couple's property, awarding Joanna half of the portion of Robert's Fidelity IRA that came from his wages during the marriage and half of the equity in the house, while confirming Robert's business interest as his separate property. The court later ordered Robert to pay Joanna $30,304 in attorney fees. Both sides appealed. The Nevada Court of Appeals resolved the appeal in four main parts. First, it upheld the ruling that the premarital agreement was valid. Because the agreement chose Pennsylvania law, the court applied Pennsylvania contract principles, under which signed agreements are presumed valid and a person challenging one must prove it invalid by clear and convincing evidence. The district court had found that Joanna generally understood the agreement's purpose, could read and write English at the time, and that both parties handwrote on the agreement, "I choose to waive representation by an attorney." The district court was not persuaded that her pregnancy and immigration status amounted to duress, and the Court of Appeals concluded those findings were supported by substantial evidence. Second, the Court of Appeals reversed the award to Joanna of half of the marriage-era contributions to Robert's Fidelity IRA. Although the agreement never specifically said Robert's wages would be his separate property, its plain language released each spouse's rights to "[a]ny and all rights to any property of the other party titled in the other parties' sole name, whether before or after the marriage." Because the IRA was solely in Robert's name, the court held it remained his separate property even though marital wages went into it. For the same reason, the court reversed the ruling giving Robert a community interest in Joanna's own solely titled Fidelity IRA. Third, on the house, the Court of Appeals held the district court applied the wrong legal framework. The district court had used Nevada's "gift presumption" caselaw - the idea that when a spouse signs over title, she is presumed to have gifted her interest - and found Joanna rebutted that presumption with evidence that the house was titled in Robert's name only because of her credit problems, was paid for from a joint account, and that Robert admitted in an audio recording he had promised to put her name on the house and still "owed" it to her. The appellate court said that under the premarital agreement's plain language, property titled in one spouse's name stayed separate, so the gift-presumption analysis was error. But it concluded the substance of Joanna's argument and the district court's findings pointed to a different doctrine: "constructive fraud" - a breach of the special duty of trust spouses owe each other, which can allow a court to impose a "constructive trust" recognizing that an asset is actually co-owned despite how it is titled, even where a premarital agreement exists. The court vacated the ruling on the house and sent the issue back for the district court to decide whether Joanna established constructive fraud giving rise to a constructive trust. Fourth, the court rejected Joanna's argument that she was entitled to a share of the increase in value of Robert's business, Element 115. The Pennsylvania statute she relied on excludes from marital property anything the parties excluded by valid agreement, and the business was listed as Robert's separate property in the agreement's financial disclosure. Finally, because part of the property division was reversed, the court vacated the $30,304 attorney fee award. The case now returns to the district court for further proceedings consistent with the order.

Salvatore Carrera and Lori Peterson were never married but have one child together, N.P., born in 2012 and identified in the opinion as having autism. Since 2014, the parties shared joint legal custody, with Peterson holding primary physical custody (meaning the child lived mainly with her) and Carrera having parenting time. In 2024, after Carrera sought changes, the parties agreed to keep that arrangement, with Carrera having parenting time in Texas. In March 2025, Carrera again asked the court to change custody. His request centered on an October 2024 incident in which Daniel, Peterson's ex-husband with whom she had reconciled and was living, was arrested for domestic violence against Peterson. Carrera argued that he should get primary physical custody and be allowed to move N.P. to his home in Texas, pointing to domestic violence in Peterson's home, alleged neglect, and instability, and saying his own home was stable and could provide therapy and educational resources for N.P.'s autism. The district court held an evidentiary hearing where Carrera, Peterson, Daniel, Peterson's sister, and three sheriff's deputies testified. The judge found, by a preponderance of the evidence (meaning "more likely than not"), that N.P. had lived in a home where domestic violence occurred, and even found that this factor favored Carrera. But weighing all the relevant factors together, the court concluded that N.P.'s best interest was served by staying with Peterson. The judge emphasized N.P.'s special needs, the value of stability, N.P.'s close relationship with both Peterson and Daniel, and that Daniel had been a consistent parental presence. The court denied Carrera's requests. On appeal, the Court of Appeals affirmed. It explained that a judge's custody decision is reviewed only for "abuse of discretion" - the court will overturn it only if no reasonable judge could have reached the same conclusion. The appeals court rejected each of Carrera's arguments: On the excluded 9-1-1 recordings, the court said Carrera never identified who made the calls, either below or on appeal, so he did not show the trial judge was wrong to exclude them for lack of authentication. On his other evidentiary complaints, the court said he only pointed to transcript page numbers without making a developed argument, so it would not consider them. On the discovery issue, Carrera argued that because Peterson did not timely respond to his "requests for admission" (written questions a party must admit or deny), those matters should have been automatically treated as admitted. The court held that even if the trial judge erred, any error was harmless: Carrera was allowed to question Peterson about the same subjects at the hearing, and the judge decided the case on its merits. The court also noted that in custody cases involving domestic violence, all information must be considered, and sanctions that block evidence are disfavored. On domestic violence, the court held that the special rebuttable presumption in NRS 125C.0035(5) did not apply because that presumption only applies when a parent or another person seeking custody committed the violence - and Daniel was neither a parent nor seeking custody. The court found the trial judge did properly consider the domestic violence as a best interest factor. On the remaining best interest findings and the bias claim, the court held Carrera did not show the findings lacked support or that the judge acted out of improper bias. The appeals court also stressed that it could not reweigh evidence or credibility.

Lynn and Douglas McKendry divorced in 2020. As part of their property settlement, they agreed to keep owning two California homes together after the divorce - one in Palm Desert and one in South Lake Tahoe. Lynn was responsible for the Palm Desert debts, and Douglas for the South Lake Tahoe debts. In 2023, Lynn asked the court to enforce the agreement, saying Douglas had not paid the South Lake Tahoe bills. During a court hearing, the two reached a new, comprehensive settlement resolving all their disputes. Under the resulting amendments to the divorce decree, they agreed to list the South Lake Tahoe home for sale by May 2024, with Douglas "take[ing] the lead" in dealing with the realtor while keeping Lynn informed through his lawyer. They would split the sale proceeds equally after paying off the mortgage, and both agreed to stay out of the home and remove their belongings so it could sell quickly. Lynn also agreed to buy out Douglas's interest in the Palm Desert home. In October 2024, Douglas went back to court, claiming Lynn had moved into the South Lake Tahoe home and was blocking its sale by refusing to cooperate or communicate with him. The district court found the property had not sold because of the parties' dispute and that foreclosure was imminent. To prevent the asset from being lost, the court gave Douglas legal authority to list the property, hire a realtor, and accept an offer on behalf of both parties; barred Lynn from interfering with the sale; and allowed Douglas to retrieve his personal belongings. Lynn appealed. The Court of Appeals rejected each of her arguments. First, it held the district court acted within its authority in letting Douglas oversee the sale and in directing that sale proceeds go into his lawyer's trust account - an account lawyers must maintain to safeguard money belonging to clients and other people. To the extent Lynn argued Douglas should have sold his share of the home to her instead, the court noted the amendments never provided for one party to buy out the other's equity in that property, and courts cannot rewrite an agreement to add terms the parties never agreed to. Second, the court held that even though the property sits in California, the Nevada court had authority to act because it had personal jurisdiction over both parties - meaning power over the people themselves - and that jurisdiction continued through post-divorce proceedings arising from the original case. Third, Lynn claimed the district judge was biased against her based on a personal relationship with Douglas's lawyer. The court found she did not describe the relationship and pointed only to the judge's acceptance of a routine filing showing a realtor had been hired. That single act, the court said, did not show bias, and Lynn had not shown the kind of "deep-seated favoritism or antagonism that would make fair judgment impossible" needed to disqualify a judge. Finally, Lynn argued that she agreed to the settlement under duress, which would make the amendments to the decree void. Because that argument attacked the amended decree itself, and Lynn never filed a timely appeal from that decree, the appellate court concluded it lacked jurisdiction - legal power - to consider that part of her appeal and dismissed it.

Dirk and Valerie Paul married in July 2017, had two children, and divorced after Dirk filed for divorce in March 2022. Before trial, they agreed on custody, child support, and alimony. The trial then focused on how to divide the property they acquired during the marriage (called "community property" in Nevada) and how much Dirk owed in unpaid child support that had built up while the case was pending. The district court decided Dirk was holding more of the couple's shared property than Valerie, so it ordered Dirk to make an "equalization payment" of $105,414 to Valerie - a payment meant to even out the split. A big part of that decision rested on $100,000 Dirk took out of a Wells Fargo account after the couple separated. Dirk said that money went to repay a loan from his mother and grandmother that the couple had used to buy or fix up the marital home. The court also found Dirk owed $16,745 in back child support, ordered him to keep paying $1,000 a month in child support (an amount the parties had agreed to), and said it would later issue a separate order awarding Valerie attorney fees. On appeal, the Court of Appeals addressed three issues. First, on the money question: the appellate court agreed with the district court that the $100,000 was community property and not repayment of a family loan. Dirk had no documents proving the loan or how the money was spent, his testimony and his mother's testimony did not match up, and the trial judge found them not credible. Appellate courts do not second-guess a trial judge's decisions about who is telling the truth. So the finding that the $100,000 was shared property stood. But the appellate court found a separate problem: even accepting that the $100,000 was community property, the actual dollar figure the court ordered - $105,414 - ended up giving Valerie more than half of the couple's shared property. Nevada law generally requires an equal split unless there is a "compelling reason" for an unequal one, and if a judge splits things unequally, the judge must write down the reasons. The district court did not make those findings, so the appellate court reversed the property award and sent it back for the district court either to divide things equally or to explain in writing why an unequal division is justified. Second, on child support: because the parties had agreed on the $1,000 monthly amount before trial and Dirk never raised his objection with the district court, the appellate court held he gave up (forfeited) the argument on appeal. If he wants to change the amount, he must first ask the district court to modify it. Third, on attorney fees: the district court had only said it intended to award fees and had asked Valerie's lawyer to submit more information; it had not yet entered an actual order setting an amount. Because no final fee order existed when Dirk filed his appeal, there was nothing final for the appellate court to review. The court dismissed that part of the appeal without prejudice, meaning Dirk can challenge the fee award later once a final order is entered.

Bryce Wolfe and Taylor Mannion (now Taylor Clayton) share a young daughter, E.W., born in March 2022. According to the opinion, E.W. is nearly blind, has a growth-hormone deficiency, and has several developmental delays. In 2023, the parents mediated an agreement to share joint legal and joint physical custody, and the district court adopted that agreement, setting up a schedule where E.W. rotated between her parents every two or three days. Things changed when Taylor became engaged to a military servicemember being transferred to a base near San Diego, California. In February 2024, Taylor asked the court for primary physical custody and permission to move to California with E.W. Bryce opposed that request and asked for primary physical custody himself. By the time of the hearing, Taylor had married. At a January 2025 evidentiary hearing, both parents testified. Even though Taylor had asked for primary custody, she said she would be open to continuing to share custody, suggesting a two-weeks-on, two-weeks-off arrangement. She testified that E.W. needed regular specialist visits and twice-weekly therapy, but said she was not worried about continuity of care as long as E.W. had insurance and providers in both states. Bryce disagreed that a long-distance shared arrangement was in E.W.'s best interest, emphasizing E.W.'s need for stability, the difficulty of long car trips, and the importance of consistent therapists. At one point, Bryce told the court "it would be up to what you decide" because he "do[es]n't set custody . . . for a living." In March 2025, the district court denied both parents' requests for primary physical custody and effectively denied Taylor's request to relocate. The court found that Taylor had a good-faith reason for the move but had not shown that relocation was in E.W.'s best interest or offered an actual advantage. The court found that all of the best-interest factors were either neutral or did not apply, and concluded that both parents were fully capable of caring for E.W. The court kept joint physical custody in place, but — to address Bryce's concern about frequent travel — ordered a one-month-on, one-month-off schedule instead of the two-week rotation Taylor had suggested. On child support, the court kept the baseline obligation at $0 because the parents' incomes were similar, but ordered Taylor to pay Bryce $100 per month for transportation costs tied to her decision to relocate. Bryce asked the court to reconsider its custody and parenting-time decisions (but did not separately challenge the $100 transportation award), and the court denied that request. He then appealed. The Court of Appeals rejected each of Bryce's arguments. It held that his due process rights were not violated, because Nevada's custody statutes put him on notice that joint physical custody was a possible outcome once custody was before the court, and he had a chance to be heard on the issue. It held that the court did not abuse its discretion in finding a substantial change in circumstances (relying on a prior Nevada Supreme Court case involving a relocating military spouse) or in finding that joint custody with a monthly schedule served E.W.'s best interest — noting that much of Bryce's argument amounted to asking the appellate court to reweigh the evidence, which it does not do. Finally, it held that the court properly handled the $100 transportation award as part of the overall child support determination and that Bryce had not built a record showing the amount was inadequate. The court affirmed.

Anthony Ibanez and Patamawadee Chaisawang were never married but have a child together, born in September 2021. In June 2023, Ibanez filed a court complaint asking for sole legal and primary physical custody after Chaisawang moved from Nevada to California with the child. He argued that Chaisawang had taken the child without his permission—an "abduction"—and asked that the child be returned to Nevada. Chaisawang responded, denied taking the child improperly, and formally asked the court for permission to relocate to California with the child. After a trial where both parents testified and submitted evidence—including text messages between them and a statement Ibanez gave to police the day after Chaisawang moved—the district court gave the parents joint legal custody, gave Chaisawang primary physical custody, and allowed her to relocate to California. The court also set a child support amount. Ibanez then filed a motion asking the court to reconsider its custody decision, arguing the court used the wrong legal standard when evaluating whether an abduction occurred and improperly relied on things that happened after the move. The court denied that motion and later issued a separate order setting Ibanez's monthly child support obligation at $959.33, based on a gross monthly income of $9,116.67 and a $250 reduction for transportation costs. On appeal, Ibanez raised several arguments. First, he said the court used a stricter standard of proof ("clear and convincing evidence") when deciding whether an abduction happened, when it should have used the lower "preponderance of the evidence" standard (meaning "more likely than not"). The appeals court disagreed. It explained that while the trial court had referenced a subsection dealing with a special legal presumption against parents who commit abduction, the court also analyzed the abduction question under the ordinary best-interest factor and later clarified in writing that it had applied the "more likely than not" standard. The appeals court found Ibanez did not show the wrong standard was used. Second, Ibanez argued that the evidence proved Chaisawang abducted the child and that recognizing this would have shifted other factors in his favor. The appeals court noted that the trial court repeatedly declined to find an abduction, and that its findings—based on testimony and text messages showing Chaisawang had tried to reach a custody agreement while Ibanez refused to compromise—were supported by adequate evidence. The court emphasized that weighing evidence and judging witnesses' credibility is the trial court's job, and an appeals court does not re-weigh that evidence. Third, Ibanez challenged the decision letting Chaisawang relocate to California, saying the court improperly relied on benefits that only existed because of the move (like a California school). The appeals court explained that when there is no prior custody order, a parent still needs court permission to move a child out of state, and the court must decide what is in the child's best interest. The trial court found a "sensible, good faith reason for the move"—a better school with services for the child's speech delay, nearby family, and Chaisawang's flexible remote work. The trial court also clarified that it relied on forward-looking, prospective benefits rather than benefits that had already accrued from the move. Fourth, Ibanez challenged the child support calculation, saying the court overstated his income. The appeals court found the income figure was supported by evidence: his own disclosure form showing $6,516.67, plus regular monthly transfers of at least $1,500 from his grandmother, plus $1,100 in rental income. The court also noted Ibanez received the $250 transportation reduction he had requested. Finally, Ibanez argued the court wrongly denied him attorney fees because Chaisawang caused the litigation by abducting the child. Because the appeals court had already upheld the finding that there was no abduction and no abuse of discretion in the custody decision, it found no abuse of discretion in denying attorney fees. The court affirmed all the district court's orders.

This case involves a father, Terrell Avalon Lancaster, who was ordered to pay child support for his minor child with Kenita Lamar Bauerle. The Clark County District Attorney's Family Support Division (a government office that handles child support enforcement) started the process in September 2022. Lancaster signed a document accepting service of the paperwork in November 2022, and later signed an "order upon consent" - a document in which he acknowledged he was the child's father and agreed to pay child support and past-due support (arrears). That order was formally entered by the court in December 2022. In July 2025, DAFS asked the court to enforce the order, claiming Lancaster had not been paying. Lancaster fought back, asking the court to throw out (set aside) the order he had signed. He gave several reasons: that he was pressured into signing because a DAFS representative allegedly threatened him with arrest and loss of his driver's license; that the order was the product of a "bait and switch"; and that he was tricked into signing the acceptance of service and was never actually given the paperwork, which he argued meant the court never had proper authority (jurisdiction) over him. A hearing master (an official who hears the matter and makes a recommendation to the judge) recommended denying Lancaster's request. The hearing master found that some of Lancaster's arguments were filed too late - beyond the six-month deadline that applies to certain requests to undo a judgment - and that Lancaster had accepted service and was properly served. The hearing master also found that Lancaster gave up his right to object to the court's authority over him because he did not raise that objection in a timely way. The district court agreed with the hearing master, and Lancaster appealed. The Court of Appeals affirmed. It concluded that the district court has authority over child support cases, and that Lancaster did not show otherwise. On the question of authority over him personally, the court found the hearing master's conclusion - that Lancaster accepted service and was properly served - was supported by adequate evidence. The court also noted that Lancaster waived (gave up) his ability to challenge that authority by not raising it in a timely manner. The court found his fraud-based argument was filed too late under the six-month rule. The court also rejected Lancaster's claim that the record was "forged" because the hearing master had said out loud during the hearing that he would pause (stay) the matter but then issued a written decision denying relief. The court explained that a judge's spoken statement in court is not binding, and a judge may enter a written order that differs from what was said aloud. Finally, the court declined to address Lancaster's argument about "prosecutorial misconduct," finding he did not explain it clearly enough for the court to consider it. The court also denied an emergency motion Lancaster filed to strike the record on appeal.

Dirk and Valerie Paul married in July 2017, had two children, and divorced after Dirk filed for divorce in March 2022. Before trial, they agreed on custody, child support, and alimony. The trial then focused on how to divide the property they acquired during the marriage (called "community property" in Nevada) and how much Dirk owed in unpaid child support that had built up while the case was pending. The district court decided Dirk was holding more of the couple's shared property than Valerie, so it ordered Dirk to make an "equalization payment" of $105,414 to Valerie - a payment meant to even out the split. A big part of that decision rested on $100,000 Dirk took out of a Wells Fargo account after the couple separated. Dirk said that money went to repay a loan from his mother and grandmother that the couple had used to buy or fix up the marital home. The court also found Dirk owed $16,745 in back child support, ordered him to keep paying $1,000 a month in child support (an amount the parties had agreed to), and said it would later issue a separate order awarding Valerie attorney fees. On appeal, the Court of Appeals addressed three issues. First, on the money question: the appellate court agreed with the district court that the $100,000 was community property and not repayment of a family loan. Dirk had no documents proving the loan or how the money was spent, his testimony and his mother's testimony did not match up, and the trial judge found them not credible. Appellate courts do not second-guess a trial judge's decisions about who is telling the truth. So the finding that the $100,000 was shared property stood. But the appellate court found a separate problem: even accepting that the $100,000 was community property, the actual dollar figure the court ordered - $105,414 - ended up giving Valerie more than half of the couple's shared property. Nevada law generally requires an equal split unless there is a "compelling reason" for an unequal one, and if a judge splits things unequally, the judge must write down the reasons. The district court did not make those findings, so the appellate court reversed the property award and sent it back for the district court either to divide things equally or to explain in writing why an unequal division is justified. Second, on child support: because the parties had agreed on the $1,000 monthly amount before trial and Dirk never raised his objection with the district court, the appellate court held he gave up (forfeited) the argument on appeal. If he wants to change the amount, he must first ask the district court to modify it. Third, on attorney fees: the district court had only said it intended to award fees and had asked Valerie's lawyer to submit more information; it had not yet entered an actual order setting an amount. Because no final fee order existed when Dirk filed his appeal, there was nothing final for the appellate court to review. The court dismissed that part of the appeal without prejudice, meaning Dirk can challenge the fee award later once a final order is entered.

Logan Fondren and Vanessa Lopez were married in January 2008 and have one child, born in January 2009. When they divorced in March 2010, the court adopted their settlement agreement: both parents shared legal custody, Vanessa had primary physical custody, and Logan paid $747 per month, representing child support and half of the child's health care costs. That figure was based on Logan earning $3,750 per month at the time. In January 2025, Vanessa - with help from the Washoe County District Attorney's Family Support Division - asked the court to review and update the child support amount, something Nevada law allows on a three-year cycle. The paperwork filed before the hearing showed that Logan's income had grown substantially: his own financial disclosure form listed gross monthly income of $9,550.06, along with his household expenses, his mortgage, and roughly $491 per month spent on three children (not from his marriage to Vanessa) who lived with him. After a remote evidentiary hearing, the district court found Logan's gross monthly income to be $11,032 and applied Nevada's child support formula, which calculates support as percentages of income in tiers. The formula produced $1,321 per month; the court then added $97 for the child's health insurance and subtracted $150 because Logan was responsible for supporting one other minor child, arriving at $1,268 per month. Logan appealed. The Court of Appeals rejected each of Logan's arguments. First, it found that the record contradicted his claim that the district court ignored his higher California cost of living and his obligations to his other children: his own financial disclosure form listed those costs, the district court said it considered all the evidence, and the court specifically gave him a $150 reduction for supporting another child. Second, to the extent Logan argued that he presented additional information at the hearing itself, he never filed a transcript of that hearing with the appellate court - even though the supreme court had sent him notices explaining that requirement. When an appellant fails to provide a necessary transcript, the appellate court must presume the missing transcript supports the lower court's decision. Third, on Logan's claim that the judge was biased or unfair, the court found no evidence that the judge relied on information from outside the case or displayed the kind of "deep-seated favoritism or antagonism that would make fair judgment impossible" that the law requires before relief is warranted. The court therefore affirmed the modified child support order.

This case involves a custody fight over a child identified as A.L., the youngest of three children born to Kimberly Stevens and Jefferson Davis Laney. The couple married in 2006 and divorced under a Nevada decree in 2021. Because California was the children's "home state" under an interstate custody law called the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), the Nevada divorce decree said the actual custody arrangement would be worked out in California courts. In November 2021, a California court entered a judgment - based on an agreement the parties made (a "stipulation") - that gave Stevens primary physical custody and required Laney and the children to take part in "reunification therapy," a process meant to rebuild the relationship between the children and their father. The parties agreed this therapy was in the children's best interest, agreed to jointly pick the therapist, and agreed to follow the therapist's plan and schedule. Early attempts at reunification with two therapists failed, and those therapists reported that Stevens interfered with the process. The parties then jointly selected Dr. Donna Wilburn as the reunification therapist. In May 2023, after Nevada took over jurisdiction (California gave it up), the Nevada court began enforcing the existing reunification plan. The court ordered daily 7:00 a.m. video calls between Laney and the children, and specifically ordered that the children "shall have privacy alone with [Laney]" during those calls. Private investigators hired by Laney later observed Stevens positioning herself about sixteen feet from A.L. during a scheduled call, with an older daughter hidden under a picnic table about five feet from A.L. - people apparently not visible to Laney on the call. Investigators observed similar concealment on other dates. The case eventually went to a two-day evidentiary hearing in early 2025 on custody and contempt. By the time that hearing concluded, Dr. Wilburn testified that reunification had been achieved, that it went well after initial obstacles were resolved, and that she found no signs the children had been abused by either parent. As a "mandated reporter" (someone legally required to report suspected abuse), she made no abuse report. She recommended joint physical and joint legal custody of A.L. The district court found Dr. Wilburn and Laney credible and found Stevens's testimony inconsistent, evasive, and self-serving. The court held Stevens in contempt for violating the "privacy alone" order, imposing a 25-day jail sentence that she could avoid ("purge") by paying a $500 fine, complying with court orders, and paying certain attorney fees. On custody, the court found a substantial change in circumstances and, after going through the statutory best-interest factors, found most favored Laney. Even so, the court awarded joint physical and joint legal custody of A.L. (not primary custody to Laney), partly to preserve A.L.'s bond with her sisters and Stevens. On appeal, the court rejected each of Stevens's arguments. It held that "Kayden's Law" - a 2025 Nevada statute limiting court-ordered reunification therapy - did not apply, because the reunification requirement came from the 2021 California judgment, not from a Nevada order, and Nevada was required under the UCCJEA to recognize and enforce that judgment. The court also held that no improper delegation to the therapist occurred, that the contempt finding was proper, and that the custody modification was supported by substantial evidence. As for the fee award, the court dismissed that part of the appeal, explaining it lacked jurisdiction because the final fee order was entered after Stevens filed her notice of appeal and she never filed a separate appeal from that order. Because the judgment was affirmed and no remand was ordered, Stevens's request to reassign the case to a different judge was moot.

Phillip Grigalanz and Elizabeth Copas were once in a romantic relationship. During that relationship, Grigalanz lived with Copas and her three minor children, identified in the opinion as K.C., E.C., and J.G. Grigalanz admits he is not the biological father of any of the three children. After the relationship ended, he filed a petition asking the court to give him custody of all three children, alleging that Copas and Jose Enrique Gonzalez-Alba (whom he identified as J.G.'s biological and legal father) had failed to adequately care for the children and that it would be in the children's best interest for the court to place them with him. According to the opinion, Grigalanz never served the petition or any other filing on any of the parents. The district court held a hearing on his request for a temporary custody order and, at that hearing, orally dismissed his petition, finding that he lacked "standing" - meaning the legal right to bring the case at all. Before the court put its decision in writing, Grigalanz filed a motion asking the judge to step aside, arguing that during the hearing she raised her voice at him and judged him unfairly. The court denied that motion and then entered a written order dismissing the petition for lack of standing. Grigalanz appealed. On appeal, Grigalanz argued that a Nevada statute, NRS 125A.135, gave him standing because it defines a "person acting as a parent," and that authority from other states allows a "psychological" or "de facto" parent to seek custody. The Court of Appeals disagreed. It explained that the statute merely defines a term; it does not, by its plain wording, give a non-parent the right to seek custody in Nevada in the first place. The court noted that the definition is used in only a few statutes, such as ones dealing with modifying or registering custody orders that were originally issued by courts in other states. The court also rejected Grigalanz's reliance on the "in loco parentis" doctrine - a legal idea about someone standing in the place of a parent. The court said Grigalanz pointed to no Nevada authority using that doctrine to give an unrelated person standing to seek custody, and that in Nevada the doctrine mainly comes up in the context of "equitable adoption." The court further said it was not persuaded by cases from other states because those cases did not analyze Nevada law. Grigalanz also argued that the district court had to hold an evidentiary hearing and make findings about the children's best interests before dismissing his petition. The court rejected this too, explaining that the court did hold a motion hearing, that an evidentiary hearing is meant to resolve disputed questions of fact, and that this case turned on a purely legal question because Grigalanz conceded he was not biologically related to the children. The court also explained that best-interest findings come into play only when a court is actually deciding a custody dispute, and because Grigalanz never established standing, the court did not need to reach those factors. Because it concluded that Grigalanz failed to show standing, the Court of Appeals did not address his arguments about service or about judicial bias, and it affirmed the dismissal.

This case concerns a divorce and a fight over custody of a young child born in March 2019. Nae-Ryung Lee and Joshua Lee Perry were married and lived in San Diego, California. In October 2021, the family vacationed in South Korea, Nae-Ryung's home country. In June 2022, Joshua and the child returned to the United States and moved to Las Vegas to live with the child's paternal grandmother, while Nae-Ryung initially stayed in South Korea before joining them in Las Vegas in August 2022. After living with the family for several months, Nae-Ryung accused Joshua of "kidnapping" the child, claiming the parties had agreed to return to South Korea. She filed for divorce in Las Vegas in October 2022, asking for primary physical custody, permission to move with the child, and an order keeping Joshua from leaving the state with the child. The case had a long and tangled procedural history. The district court first decided Nevada was not the child's "home state" and threw out the custody portion of the case. Joshua appealed, and the Court of Appeals reversed, saying the trial court had failed to consider whether Nevada might have jurisdiction (the legal power to decide the case) on other grounds. Meanwhile, the child had been with Nae-Ryung in South Korea since November 2022, and Joshua filed a case there under the Hague Convention (an international agreement dealing with the return of children) seeking the child's return. Back in Nevada, the court went through several rounds of hearings, orders, motions to reconsider, and reversals of its own prior rulings. At one point it took "temporary emergency jurisdiction" and awarded Joshua temporary custody, then later set that aside, then later still—after Joshua asked it to reconsider—decided that Nevada did have exclusive and continuing jurisdiction and awarded Joshua sole legal and sole physical custody. Nae-Ryung repeatedly did not appear at hearings. Eventually, in June 2025, the court issued an amended decree giving Joshua sole legal custody and primary physical custody, with Nae-Ryung allowed weekly supervised parenting time. This appeal followed. On appeal, Nae-Ryung made three main arguments. First, she said the court improperly changed its own decree more than a year after entering it and did so without giving her notice that the result could be a final custody order against her—violating her right to due process (fair notice and a chance to be heard). The Court of Appeals disagreed. It pointed to the record showing that custody was clearly identified as an issue for the evidentiary hearing, that Joshua's motion asking the court to decide custody had been served on her, and that she had filed an opposition and received notice of the hearings she failed to attend. The court concluded she had adequate notice and an opportunity to be heard. Second, she argued the court wrongly relied on a rule meant for fixing clerical mistakes (NRCP 60(a)) to justify its decision. The Court of Appeals concluded that even if relying on that rule was an error, it was harmless because the court was actually responding to the parties' motions for reconsideration. Third, she challenged the custody awards themselves. On legal custody (the authority to make major decisions about the child's health, education, and upbringing), the court found no abuse of discretion: the trial court had pointed to Nae-Ryung withholding the child for years, ignoring court orders, and obtaining a South Korean passport for the child without Joshua's knowledge or consent—facts supporting a finding that the parents could not cooperate. On physical custody, however, the Court of Appeals found a problem. Although the trial court called its award "primary physical custody," the practical effect—weekly supervised parenting time only—amounted to "sole physical custody." Under Nevada precedent (Roe v. Roe), a sole physical custody award requires specific written findings, including either that the other parent is unfit to live with or that giving that parent significant parenting time is not in the child's best interest, plus consideration of the least restrictive parenting arrangement. The trial court did not make these required findings. The Court of Appeals therefore reversed the physical custody and parenting time decisions and sent the case back for the trial court either to give Nae-Ryung more parenting time so the arrangement is genuinely primary (not sole) custody, or to make the additional findings Nevada law requires to support a sole physical custody award.

Vick and Anjena Gill married in 2020 and had a son, K.G., who was born in Las Vegas in April 2023. About a month after K.G.'s birth, Anjena and the baby traveled to Canada for a funeral. They ended up staying longer than planned, in part because the family's Nevada home had a major water leak and Anjena found temporary work in Canada. Vick remained in regular contact, visited, and the couple even discussed having more children. At some point the marriage broke down. In November 2023, Anjena filed for custody of K.G. in a Canadian court. Vick responded by filing a Hague Convention petition in Canada seeking the child's return to Nevada; the Canadian court denied that petition, finding that K.G.'s "habitual residence" was Canada. Vick lost his appeal of that ruling. In May 2024, Vick filed for divorce in Nevada and asked the Nevada court for custody and child support. The Nevada district court refused, saying it did not have "home state" jurisdiction over the child and that a lot of litigation had already happened in Canada. Vick appealed to the Nevada Supreme Court. The Nevada Supreme Court reversed. Under the UCCJEA (Nevada's version is in NRS Chapter 125A), a state is a child's "home state" if the child lived there with a parent for at least six consecutive months before the case was filed, and that period includes any "temporary absence" from the state. The Court concluded that K.G.'s time in Canada from May to November 2023 was a temporary absence: Anjena originally went for a funeral intending to return, communicated frequently with Vick, discussed expanding the family, and the prolonged stay was due to a home repair and short-term work. The Hague proceeding itself found that Anjena did not form an intent to remain in Canada until November 2023. So for jurisdictional purposes, K.G. is treated as having lived in Nevada until November 6, 2023 - less than six months before Vick's May 3, 2024 filing. That makes Nevada the home state. However, the Court did not order Nevada to keep the case. It explained that the earlier Hague ruling - finding Canada to be K.G.'s habitual residence - is entitled to "considerable weight" and that international practice generally directs custody decisions to the country of habitual residence. Under NRS 125A.365(1), a Nevada court may decline jurisdiction if another forum is more appropriate. The Court said deferring to Canada "may ultimately be appropriate," but it would be premature to do so now because: (1) the Canadian court has not yet decided whether it has jurisdiction; and (2) the parties have not had a chance to brief the issue in Nevada. The Court instructed the district court on remand to try to hold a UCCJEA-style conference with the Canadian court, take briefing, and apply NRS 125A.365 to decide whether Nevada or Canada is the more appropriate forum. On the child support claim, the Court noted that custody and support typically travel together, and instructed the district court to exercise jurisdiction over both pending its decision on whether to defer to Canada. The Court did not consider Vick's separate complaint about attorney fees because the record showed no fee award had actually been entered.

A woman named Irina Spiranskaya asked the Court of Appeals of Nevada to step in and stop or correct a lower court in an ongoing family law case. She represented herself and filed what is called an "original emergency petition" for two kinds of extraordinary court orders: a writ of mandamus and a writ of prohibition. A writ of mandamus is a court order that forces a lower court or official to perform a duty the law requires, or that reins in a decision made in an arbitrary or capricious way. A writ of prohibition is a court order that stops a lower court from continuing proceedings when that court is acting beyond its legal authority - in other words, when it lacks jurisdiction. Spiranskaya argued that the district court did not have jurisdiction over her family law matter. The Court of Appeals explained that deciding whether to even take up this kind of petition is entirely within its own discretion, and that the person asking for relief carries the burden of showing it is warranted. After reviewing the petition and the documents filed with it, the court concluded that Spiranskaya had not shown that this extraordinary relief was justified. The court also addressed a specific law Spiranskaya relied on. She pointed to a Nevada statute about child custody jurisdiction. But the court noted that the statute she cited governs only the jurisdiction over initial child custody decisions - the very first custody determination in a case. Her petition, the court said, did not challenge an initial custody determination, so that statute did not support her request. For these reasons, the court denied the petition, along with any other relief she had requested.

This case involves a mother, Richard'dnae C., whose newborn daughter K.C. was taken into state custody by Clark County's child-welfare agency shortly after birth in November 2022. The agency was concerned about the mother's untreated mental illness. The mother had previously lost parental rights to six other children. The agency placed K.C. with a foster family that had already adopted K.C.'s siblings, and gave the mother a "case plan" - a list of things she had to do, like getting mental-health and substance-abuse evaluations and following the recommendations - to try to get her daughter back. She was also given a guardian ad litem to help protect her interests in the legal process. After a trial in July 2024, the family court judge ended the mother's parental rights. The mother appealed to the Nevada Supreme Court, arguing the evidence was not strong enough to justify that decision. The Supreme Court disagreed and affirmed. To end someone's parental rights in Nevada, a judge must find by "clear and convincing evidence" both (1) at least one form of "parental fault" and (2) that termination is in the child's best interest. The Court reviewed the evidence and concluded the trial judge had enough support for three forms of parental fault: the mother is "unfit" due to her mental illness (she has been diagnosed with schizophrenia and bipolar disorder and refuses to take medication or acknowledge her conditions); she failed to make the changes the case plan required (she was uncooperative at psychiatric appointments and did not change her behavior); and she made only "token efforts" to parent (K.C. lived outside her care for 20 consecutive months, she missed visits, and when she did attend she dozed off). The Court also held that termination was in K.C.'s best interest. Nevada law presumes termination is in a child's best interest when the child has been outside the parent's home for 14 of 20 consecutive months, and the mother did not produce evidence to overcome that presumption. The Court noted that K.C. has spent almost her entire life with the foster family that has already adopted her siblings. The Court declined to consider the mother's arguments about her older children, because their cases were resolved in earlier proceedings and were not part of this appeal.

Christina S. and Joshua S. were never married but share two minor children. Christina asked the family court to terminate Joshua's parental rights - that is, to legally end his status as the children's father. The district court refused, finding that ending Joshua's parental rights would not be in the children's best interest. Christina appealed, and the Nevada Supreme Court affirmed the district court's decision. To terminate parental rights in Nevada, a parent must prove two things by "clear and convincing evidence" (a high standard, more than the usual civil burden but less than the criminal "beyond a reasonable doubt"): (1) that there is at least one ground of "parental fault," and (2) that termination is in the children's best interest. Because Christina lost on the second prong, the appellate court did not need to reach the first. The court acknowledged that Joshua had serious problems. He was incarcerated at the time of trial for abusing one of the children and Christina, he had a history of domestic abuse, and he continued to minimize that history. On the other hand, the district court found that Joshua had successfully completed supervised and unsupervised visits before incarceration, was assessed as low-risk to reoffend, and was a first-time parent. A licensed clinical social worker, John S. Pacult, evaluated Joshua and concluded that reunification - subject to conditions - was preferable to termination. Christina also already has sole legal and physical custody, so Joshua poses no immediate risk to the children. Christina raised three issues on appeal. First, she objected to Pacult's expert testimony, but the Supreme Court held she could not complain on appeal because she had stipulated to his designation as an expert and did not object when his report was admitted. Under the "invited error" doctrine, a party cannot complain about errors she helped cause. Second, she argued the district court got the best-interest analysis wrong. The Supreme Court disagreed, finding "substantial evidence" supported the district court's careful weighing of the evidence, and noted that Nevada's termination statute is meant to protect children, not punish parents. Third, she argued the district court should have ordered Joshua to pay her attorney fees because he allegedly filed a motion in bad faith to remove her lawyer. The Supreme Court found no abuse of discretion in the district court's conclusion that neither party had litigated unreasonably or vexatiously. The Supreme Court also declined Christina's request to reconsider a recent decision (Matter of L.R.S.) holding that certain statutory considerations and presumptions in NRS 128.107 and NRS 128.109 do not apply to private (parent-versus-parent) termination cases.

Molly L. and Bryan T. divorced in 2014 and shared two children, with Molly having primary physical custody. In 2016, Bryan suffered a serious mental health crisis. After an incident in which Bryan drove off with the children and ended up at a hospital in distress, Molly obtained a temporary protective order (TPO) - a court order keeping Bryan away. The extended TPO required Bryan to stay away until July 18, 2017, or until he completed a psychological evaluation and counseling. Bryan was hospitalized for months, then went to live with his mother in Kansas, and later returned to Nevada believing he was barred from contacting Molly or the children. For several years afterward, Bryan had no contact with S.A.T. According to the opinion, Bryan could not afford the required psychological treatment or an attorney, repeatedly attended free "Ask-a-Lawyer" sessions, tried unsuccessfully to get mediation through the child support case, and reconnected with Molly's adult son Zachary. Meanwhile, Molly took steps that made contact harder: she moved without updating her address in the child support action, cut off ties with Bryan's family, and restricted the children's activities out of fear Bryan might find them. In 2021, Bryan received an inheritance, hired a lawyer, paid off his child support arrears, and completed the psychological evaluation and counseling the TPO had required. Soon after he provided proof of treatment, Molly filed a petition to terminate his parental rights. (One child, K.W.T., emancipated and later died by suicide during the proceedings, so the case proceeded only as to S.A.T.) After an evidentiary hearing - including testimony from the doctor who evaluated Bryan that his mental health issues were under control - the district court denied Molly's petition. The Nevada Supreme Court affirmed. The Court emphasized that a private termination case (one parent trying to terminate the other parent's rights) is different from a state-filed termination case. When the state files, the focus is the child's safety. When one parent files against the other, the child is usually already safe, so courts must look carefully at the petitioning parent's motivations. On abandonment, the Court held Bryan rebutted the presumption: he believed the TPO barred contact until he completed treatment, he could not afford that treatment or a lawyer until 2021, and he repeatedly tried to get help and eventually paid arrears and completed treatment. On neglect, the Court held there was no evidence S.A.T. was inadequately cared for - she was in Molly's care and Bryan paid child support. On "token efforts" - the idea that a parent who barely communicates with a child has shown parental fault - the Court announced a new rule: in private termination actions, courts should disfavor terminating parental rights when the only ground proved is that the parent made only token efforts to communicate with or support the child. The Court reasoned this category is uniquely vulnerable to abuse by a custodial parent who controls access to the child, and that "settled purpose" (the standard for abandonment) is the opposite of "only token efforts." The Court also rejected Molly's argument that Bryan admitted the token-efforts allegation by failing to deny it in his response. Because a responsive pleading is not required in termination cases, an undenied allegation is treated as denied, not admitted, and the underlying facts must still be proved by clear and convincing evidence. Finally, the Court declined to address whether Bryan complied with the TPO's mental-health conditions, finding that issue moot because the TPO had long since expired by its own terms.

This case concerns a father, identified as Jason V., whose parental rights to his child R.B.J. were terminated by a Clark County family court. R.B.J. was taken into protective custody at birth because the child's mother had a prior history with the Clark County Department of Family Services (DFS). Jason began working on a reunification plan, but his probation was revoked after a DUI arrest, and he was incarcerated. DFS then asked the court to terminate his parental rights, and after a trial, the court did so. Jason raised two main arguments on appeal. First, he argued that a Nevada statute - NRS 128.109 - is unconstitutional because it creates "rebuttable presumptions" against parents whose children have been in protective custody for 14 or more of the last 20 months. A rebuttable presumption means the law starts by assuming something is true (here, that termination is in the child's best interest, and that the parent has only made "token efforts"), and the parent then bears the burden of disproving it. Jason argued this shifts the burden onto parents in a way that violates due process - the constitutional guarantee of fair procedures before the government takes away something important. The Nevada Supreme Court disagreed. It explained that while parental rights are extremely important, the court has previously held that these presumptions do not create an unacceptable risk of mistaken termination, as long as the State first proves the presumption applies by clear and convincing evidence and the parent can rebut it by a preponderance (the lower "more likely than not" standard). The court also pointed out that Nevada has a strong interest in giving abused and neglected children stable, permanent homes, and that many other states have upheld similar presumptions. The court declined to consider Jason's equal-protection argument because he did not raise it in his opening brief. Second, Jason claimed the trial judge was biased and not paying attention. The court held he waived the bias claim by not asking the trial judge to step aside during the case. As for inattentiveness, the court found none: the trial judge had simply reconsidered two evidentiary rulings - admitting some dependency court records and rejecting a Sixth Amendment Confrontation Clause objection (which the court explained does not apply in civil cases like termination proceedings). The court did note, without changing the outcome, that the trial judge sometimes appeared by video while the parties and witnesses appeared in person. The court reminded lower courts that, under rules adopted after Jason's trial (ADKT 581), termination trials are presumptively to be held in person, including the judge. Finally, the court reviewed the record and found "substantial evidence" supporting termination. R.B.J. was bonded with a foster family that included his biological half-sister and wished to adopt both children, and R.B.J. was thriving in a stable home where he received occupational therapy. The trial court's findings of parental unfitness, neglect, and token efforts were supported by Jason's long history of drug use, criminal activity including domestic violence, repeated incarceration, and relapse. The court acknowledged Jason had completed some programs in prison but gave that limited weight because he had no concrete plan to address his substance abuse after release and had relapsed after similar programs before.

This case is about a mother, identified as Mary W., whose parental rights to her two children were ended by a Nevada family court. After that ruling, Mary asked the court to undo it; the court refused. She then appealed to the Nevada Supreme Court, representing herself. The Supreme Court affirmed, meaning the termination stands. Mary raised three main complaints. First, she said she was not properly told when the trial would happen, which she argued violated her right to due process (a constitutional guarantee of fair notice and a chance to be heard). The Supreme Court disagreed, pointing out that because Mary's address was uncertain, notice was delivered to her adult son and was also published, both methods Nevada law allows when a party's address is unknown. The court also noted that the trial judge told Mary the trial date out loud four times at a November 28, 2023 status hearing, and gave her the date in writing. An earlier report had listed a wrong date, but the court said that mistake did not erase the correct notice she later received. Second, Mary argued that her children were improperly taken from her in the first place, suggesting the removal was tied to her asking for a new caseworker. The court found the record told a different story: Mary had admitted using illicit drugs, the children were living in unsafe conditions (including broken glass and staples on the floor), and Mary was behaving erratically and aggressively when the children were taken into protective custody. Third, Mary challenged the legal conclusions that justified ending her parental rights. Under Nevada law, a court must find both (a) "parental fault" and (b) that termination is in the child's best interest. The Supreme Court found enough evidence on both points: Mary struggled with substance abuse, refused drug tests, did not complete a treatment program, and did not substantially complete the case plan DFS gave her. The children, meanwhile, had been living with their maternal grandmother, were attached to her, were thriving, and the grandmother wanted to adopt them. Because every one of Mary's arguments failed on the record, the Supreme Court affirmed the district court's decision.

This case involves a father, Miguel E.C., and his five minor children. In March 2025, the State of Nevada filed a petition claiming the children needed protection. According to the petition, Miguel made numerous allegations - later found to be false - that the children had been sexually abused by their mother and/or her relatives. The petition said these false claims caused the children to undergo medical examinations and to take part in investigations of their mother and relatives, that Miguel appeared to have coached the children to make the false claims, and that Miguel may have a mental health condition driving his behavior. The children were removed from Miguel's care and placed with their mother. The district court held an evidentiary hearing (a court session where witnesses testify and evidence is presented). Miguel attended and testified. Other witnesses, including detectives who investigated the sexual-abuse allegations, also testified, and documents were introduced. Afterward, the court found that Miguel had abused and neglected the children by causing them mental injury that was not accidental. The court concluded that Miguel coached and coerced the children into making false abuse allegations as a way to try to gain custody, and that this caused the children emotional harm. The court then gave the mother sole custody, ended the agency's custody, gave Miguel supervised parenting time, said any future custody changes would have to go through a regular custody court, and closed the case. On appeal, Miguel argued three main things: that the district court's findings were wrong because the State presented false evidence, that his due process rights were violated because the court made him rush through his testimony, and that the judge was biased against him. The Court of Appeals affirmed. A key reason was a record problem: Miguel filed a certificate stating he was not requesting transcripts of the hearing, so the appeals court never received a written record of what was said. Under Nevada rules, when an appellant does not provide the necessary transcript, the appeals court assumes the missing transcript supports the lower court's decision. Because of that, the court could not meaningfully review Miguel's arguments about the evidence, and it noted that appeals courts do not re-weigh a trial court's decisions about which witnesses to believe. On due process, the court found Miguel had received notice of the hearing, appeared with his lawyer, and testified - and again, without a transcript, the court presumed the record supported how the trial judge handled the time for testimony. On bias, the court found Miguel had not shown the judge relied on outside information or displayed the kind of deep-seated hostility that would make a fair decision impossible. The opinion also addressed a jurisdictional objection from the State. The State argued the appeal should be dismissed because the order with the factual findings was not a final, appealable order. The court rejected that, explaining that the order placing the children with their mother and closing the case resolved everything and was therefore a final appealable order, which also allowed the court to review earlier interlocutory (non-final) decisions.

This case arose from a child-protection proceeding. According to the opinion, a child attempted suicide, and the Clark County Department of Family Services became involved while the child was hospitalized. The Clark County District Attorney's Office then filed a petition alleging the child needed protection because of neglect and because the child faced a threat of harm while in Dawson's care. After an evidentiary hearing, the district court found that Dawson was the person responsible for the child's welfare. The court heard testimony about the suicide attempt and Dawson's actions surrounding it, including her failure to take immediate action after finding the child's suicide note and allowing the child access to a firearm despite the child's mental health difficulties and prior suicide attempts. The district court found it was foreseeable that the child could try to commit suicide on the relevant night and that Dawson exhibited "almost a depraved indifference for this child's wellbeing and safety." While the court found insufficient evidence for the separate threat-of-harm allegation, it concluded the neglect allegation was substantiated and placed the child in Family Services' custody. Dawson asked the Court of Appeals for a writ of mandamus — an extraordinary court order compelling a lower court to perform a legally required act or correcting an arbitrary or capricious exercise of discretion. The Court of Appeals explained that this kind of relief is discretionary and that the person asking for it bears the burden of showing it is warranted. Because placement decisions in dependency cases are entrusted to the district court's discretion, with the child's best interest as the main consideration, Dawson had to show the lower court manifestly abused that discretion or acted arbitrarily or capriciously. The Court of Appeals concluded she did not make that showing. It emphasized that it is not at liberty to reweigh the evidence or the district court's credibility determinations, and it denied the petition.

This case is about whether a child-welfare agency and the children themselves can appeal when a juvenile court dismisses a petition asking the court to protect the children from a parent. The petition here was filed under NRS Chapter 432B, the Nevada law that governs child-protection proceedings. After a hearing, the juvenile court found the abuse and neglect allegations against the father were not proven and threw the case out. CCDFS and the children tried to appeal that dismissal. The problem was a 2012 Nevada Supreme Court decision called In re A.B., which had said that orders coming out of juvenile proceedings involving child custody are not appealable - meaning the only way to challenge them in the Supreme Court was to file a writ of mandamus (a separate, more limited type of court request). The Supreme Court flagged this issue on its own and asked the parties to explain why the appeal should not be tossed out. The Supreme Court took a fresh look at the question and decided that In re A.B. got it wrong on this point. The court explained that Nevada Rule of Appellate Procedure 3A(b)(1) allows appeals from a "final judgment" entered by a district court, and that an order completely dismissing a child-protection case fits that definition because it ends the case and leaves nothing further for the court to decide. A juvenile court is part of the district court, so its final orders qualify. The father argued that a different rule, NRAP 3A(b)(7), which addresses appeals from certain child-custody orders that do not arise in juvenile court, blocks appeals from juvenile-court custody orders. The court rejected that reading. NRAP 3A(b)(7) by its terms simply does not cover juvenile-court custody orders; it does not strip away the appeal right that NRAP 3A(b)(1) provides for final judgments. The court therefore overruled In re A.B. in part - specifically, the part holding that all child-custody orders arising from juvenile proceedings are unappealable. The court was careful to limit its ruling: only orders that finally resolve NRS Chapter 432B proceedings are appealable under NRAP 3A(b)(1). Interlocutory (mid-case) child-custody orders entered in those proceedings are still not appealable under this rule. Because the order in this case completely ended the child-protection proceedings, it is a final judgment, and the appeal may go forward. The court gave the appellants 60 days to file their opening brief.

J.B. was taken into protective custody two days after his birth and placed by DFS with Becky and Jay Whipple, a "fictive kin" placement (caregivers treated as family even though not biologically related). After paternity was established, the district court at one point ordered J.B. placed with his paternal grandfather. The Nevada Supreme Court reversed that placement in 2024. After further proceedings, the district court held an evidentiary hearing and placed J.B. with the Whipples. But as part of that order, the judge also gave the grandfather "significant" visitation rights and said those rights would continue even if the Whipples eventually adopted J.B. DFS asked the Supreme Court to order the visitation portion vacated. The Supreme Court agreed with DFS. Before reaching the merits, the court rejected an argument that DFS lacked "standing" (the legal right to bring the challenge). Because DFS had protective custody of J.B. and Nevada law gives DFS duties over a child's placement while in protective custody, DFS had a sufficient interest to challenge the order. On the merits, the court explained that the statute the district court relied on - NRS 125C.050 - allows grandparents to seek visitation only in specific circumstances, including when a parent's rights have been "relinquished or terminated." Here, although the parents had signed relinquishment paperwork, the relinquishments had not been finalized when the district court entered the order. Because no parental rights had actually been relinquished or terminated yet, the statutory trigger for grandparent visitation under NRS 125C.050 had not been met. The court held the district court therefore could not grant grandparent visitation under that statute and noted that any grandparent visitation in this posture would have to come through the district court's authority under NRS Chapter 432B. The court directed the district court to vacate the visitation portion of the placement order.

Two people, Antwann B. and Jessica B., asked the Court of Appeals of Nevada to step in and stop or override what a lower court (the family division of the Eighth Judicial District Court in Clark County) was doing in a case involving child welfare under NRS Chapter 432B, which governs the protection of children from abuse and neglect. They filed their request without a lawyer, representing themselves. The type of relief they sought is called an "extraordinary writ" - specifically a writ of mandamus or a writ of prohibition. A writ of mandamus is a court order forcing a lower court or official to perform a duty the law requires, or to correct an arbitrary or capricious use of discretion. A writ of prohibition is an order stopping a lower court from acting beyond, or without, its jurisdiction (its legal authority to hear the case). The Court of Appeals explained that deciding whether to even consider this kind of petition is entirely within its own discretion, and that the people asking for the writ carry the burden of showing that such relief is justified. After reviewing the petition and the documents submitted with it, the court concluded that the petitioners had not shown that extraordinary relief was warranted, and it denied the petition. Because the court denied the petition, it also denied as moot (no longer requiring a decision) an emergency motion the petitioners had filed on October 24, 2025.

This case concerns a guardianship — a legal arrangement in which a court gives someone other than a child's parents the authority to care for that child. In April 2017, a Clark County family court granted Joelle Reed and Carolyn Louise Reed guardianship over two minor children, E.I.C. and E.M.D. The guardians, who had already been caring for the children, said the children's parents could not care for them. Over the following years, Richard Clements — E.I.C.'s father — repeatedly tried to end the guardianship over his daughter, without success. In September 2025, Richard filed what he called an emergency motion to vacate (cancel) the guardianship. His main argument was that the original 2017 order should be treated as void — legally invalid from the start — because he had never been properly served with (formally given legal notice of) the guardianship petition. He relied on a court rule, NRCP 60(b)(4), which allows a court to set aside a judgment that is void. He claimed the district court had previously acknowledged there was no proof of proper service in the record, argued the court had used an improper standard in rejecting his earlier attempts, and asserted that the court's repeated errors showed judicial corruption in his case. He asked the court to declare all the guardianship orders void and end them immediately, or, if the court reached the merits, to terminate the guardianship or hold a hearing. The district court denied his motion for two independent reasons. First, it found that Richard had not properly served his own motion on the appropriate parties. Second, addressing the substance anyway, the court found that the service issue had already been decided against Richard in earlier proceedings — meaning it was, in the court's words, "res judicata" (an issue already finally decided and not open to relitigation) — and that Richard had not offered facts showing that ending the guardianship would be in E.I.C.'s best interest. On appeal, the Court of Appeals pointed out that Richard did not meaningfully argue against the first reason the district court gave — his failure to serve his own motion. Because that was an independent ground for the denial and he did not challenge it, the appellate court treated any argument about it as given up (forfeited), which by itself was enough to uphold the denial. The court then went on to address Richard's actual arguments. It reviewed the district court's decision for what is called an "abuse of discretion" — a standard under which an appellate court does not substitute its own judgment but asks whether the lower court acted within its lawful range of choices. The court found that the record supported the district court's conclusions. An August 2023 order had already found that notice for the original guardianship was sufficient and that the guardians were credible about the service issue, and the district court had already considered and rejected Richard's service arguments before. The appellate court also noted that because the guardians were appointed in April 2017, Richard bore the burden of showing, by clear and convincing evidence, that ending the guardianship was in E.I.C.'s best interest — and his motion focused only on the 2017 procedure, not on the child's best interest. For those reasons, the court concluded Richard had not shown the district court abused its discretion, and it affirmed.

The Ruckles had been serving as court-appointed guardians of their three granddaughters since January 2022, when a district court found that the children had been living with their mother, Sara Q., in squalid conditions and were thriving in the Ruckles' care. Over the next two years, Sara petitioned the court to begin reunification therapy - therapy designed to repair the relationship between a parent and her children - and the court eventually ordered the Ruckles, Sara, and the children to participate with a therapist named Dr. Stephanie Holland. Disagreements arose over the wording of the therapist's consent paperwork, and the therapy was slow to begin. Dr. Holland sent the court two confidential reports under NSRG 5, a rule that allows a guardianship judge to receive certain communications about a guardian's conduct or a protected person's welfare. After receiving the second report, the court issued a July 13, 2024 order expressing "significant concern" about the Ruckles' compliance with their duties, ordered the children to undergo psychoeducational testing, expanded Sara's visitation, and set an NSRG 5 hearing for July 25 to address the issues raised in Dr. Holland's report. One day before that hearing, Sara filed a petition asking the court to remove the Ruckles and terminate the guardianship. The court did not issue the formal "citations" (legal notices) that Nevada statutes require when such a petition is filed, and there is no indication the petition was set for any hearing. At the July 25 hearing, which lasted only seven minutes, the district court announced - without taking evidence, hearing argument, or directing briefing - that it was removing the Ruckles as guardians and terminating the guardianship. When the Ruckles' lawyer tried to speak, the judge said, "I understand you've stood up, but I've made my orders. I am terminating the guardianship today." The court told counsel he could file a motion for reconsideration. A written order followed in October 2024. The Ruckles appealed, arguing that they had a constitutional right to procedural due process - basic fairness, including notice and a chance to be heard - before a court could strip them of guardianship, and that they did not get either. The Court of Appeals agreed. Building on the Nevada Supreme Court's 2023 decision in In re Guardianship of D.M.F., the Court of Appeals expressly held that a custodial relative who serves as a guardian has a constitutionally protected liberty interest in the care, custody, and management of the child, and is therefore entitled to notice and an opportunity to be heard before a court may, on its own initiative, remove the guardian and terminate the guardianship. The court found the notice given here was inadequate. The July 13 order flagged concerns but did not signal that removal or termination was being considered. Sara's last-minute petition came too late and was not accompanied by the statutorily required citations. And even if notice had been adequate, there was no meaningful opportunity to be heard because the district court issued its ruling at the start of a brief hearing, without briefing, evidence, or argument. Rather than simply reversing, the Court of Appeals vacated the order and sent the case back. Because Dr. Holland's confidential reports were not in the appellate record - and because Sara's petition described serious allegations including alleged emotional, psychological, and physical abuse and educational neglect - the court directed the district court on remand to permit briefing, hold an evidentiary hearing, and make the specific findings required by Nevada statutes and the NSRG before deciding whether removal or termination is warranted. In the meantime, the children will remain in Sara's physical and legal custody pending the district court's decision, although the trial court retains authority to enter temporary or emergency orders if circumstances require. The Court of Appeals also noted that the matter is moot as to the eldest child, A.L.R.-Q., because she has turned 18.

This case is a dispute between two grandmothers over who would serve as legal guardian for a young girl, M.J.V. She was born in 2017 with a radial ray malformation in her right arm (no radial bone or thumb). Because both of her parents had substance abuse issues, her maternal grandmother, Brenda, and step-grandfather, Randy, took her home from the hospital, raised her for roughly five-and-a-half years, and received guardianship over her. During that time they handled all of her medical care, consulted orthopedic specialists, and enrolled her in early intervention programs. About five years later, M.J.V.'s father, Kameron, got sober and gradually re-entered her life. When the district court held a hearing on whether Kameron would regain custody, Brenda and Randy failed to appear, purportedly because they were unaware of the hearing date. The court terminated their guardianship and awarded Kameron custody. Four months later, Kameron died in a work-related accident. After Kameron's death, both grandmothers sought guardianship. Kelly, Kameron's mother, petitioned the day after he died and was awarded temporary guardianship. Brenda and Randy received court-ordered visitation every other weekend and then filed their own competing petition. The relationship between the two households was not positive: Brenda and Randy complained that Kelly restricted visitation to the very letter of the court order and that her communication was "[l]imited and late," while Kelly disagreed with Brenda and Randy's decision to skip M.J.V.'s therapy appointments during their visitation time and believed M.J.V. needed to stay with her for stability. After a three-day evidentiary hearing, the district court awarded guardianship to Brenda, with Kelly receiving visitation every other weekend and on holidays. In a later written order, the court found that both sides loved M.J.V. and were credible but had serious animosity toward each other, and it based its decision on four findings: Brenda would be more likely to facilitate a good relationship between M.J.V. and Kelly; Brenda was better equipped and organized to handle M.J.V.'s medical needs; Brenda could provide better living conditions; and Brenda was in better physical and mental condition to care for M.J.V. Notably, both the GAL (a court-appointed advocate for the child) and the ACORN representative had recommended that Kelly receive the guardianship. On appeal, the Nevada Court of Appeals affirmed. It explained that appellate courts do not reweigh evidence or second-guess a trial court's factual findings so long as those findings are supported by substantial evidence - "evidence that a reasonable person may accept as adequate to sustain a judgment." The court found substantial evidence supporting each of the district court's challenged findings: Kelly had rigidly restricted visitation and communicated sparingly, while Brenda had a history of allowing family contact, including cautiously allowing Kameron back into M.J.V.'s life; Brenda had managed M.J.V.'s medical care for years and kept detailed handwritten records; and Kelly had chronic conditions (fibromyalgia and lupus, with the former requiring doctor-prescribed oxycodone), while Brenda had passed a physical examination as part of a foster-parent vetting process. The court also rejected Kelly's argument that the district court had to walk through the child-custody best-interest factors in NRS 125C.0035(4): those factors may be considered in a guardianship case but are not mandatory. Nor was the district court bound to follow the GAL's and ACORN representative's recommendations - it had to consider them, and it did, but each recommendation is only one factor among many. Finally, although the district court's order used the phrase "sole legal custody" - terminology that ordinarily applies to parents - any mistake in wording was harmless because the guardianship award itself gave Brenda the legal authority to make medical, educational, and similar decisions for M.J.V.

This case concerns a teenager, Z.B., who was adopted by Alexis B. in 2013 after the parental rights of her biological mother, Michelle Simms, were terminated. In September 2022, Z.B. left Alexis's home and began living with biological family members, including Simms. Over the next five months, Alexis reported Z.B. as a runaway and asked law enforcement and child welfare agencies to conduct welfare checks at Simms' home, which they did. In March 2023, Simms petitioned the district court to be appointed as Z.B.'s guardian. Alexis opposed that petition and filed her own competing petition seeking guardianship. After an evidentiary hearing, the district court denied both petitions, finding that no guardianship was needed because Z.B. already had a parent (Alexis) willing and able to care for her. Z.B. appealed. The Nevada Supreme Court affirmed. The court explained that under Nevada law, a parent is preferred over others as guardian if qualified and suitable, and the person seeking guardianship must prove by clear and convincing evidence that a guardianship is necessary. The district court found Alexis could meet Z.B.'s basic needs and did not pose a safety risk. The district court also found that Z.B.'s claims of physical abuse by Alexis were not credible, and the Supreme Court explained it would not second-guess the district court's credibility determinations on appeal. The court rejected Z.B.'s argument that Alexis had abandoned her. A statutory presumption that a parent is unsuitable applies when the child has been out of the parent's care for the six months immediately before the petition is filed, but here Simms filed the petition just short of six months after Z.B. left Alexis's home, so the presumption did not apply. The record also showed Alexis made consistent efforts to bring Z.B. home. The court also addressed Z.B.'s argument that the district court ignored her preference (Z.B. wanted Simms to be her guardian). The court noted the district court had acknowledged Z.B.'s wishes in its written order, and in any event Z.B.'s preference could not override the conclusion that a guardianship was not necessary.

H.B. is a minor who lost his father and, after a period of homelessness with his mother, began living with his uncle, Marques. Marques asked the family court to make him H.B.'s legal guardian. Marques disclosed up front that he had a felony conviction (for attempted murder, in 2008) and was on parole. H.B.'s paternal grandmother appeared at the hearing supporting Marques, and Marques said H.B.'s mother also supported the arrangement by text message. The district court denied the petition with prejudice for two reasons. First, the judge concluded that Marques's felony conviction automatically disqualified him from being a guardian. Second, the judge found that Marques had not properly served notice of his petition on H.B.'s mother and other close relatives, as Nevada's guardianship statutes require. The Nevada Supreme Court agreed with H.B. and Marques on the first point. Reading the statute that lists the things a court must consider in deciding whether someone is fit to serve as guardian, the court held that a felony conviction is one factor the judge must weigh - but it is not an automatic bar. The Legislature did not write an automatic disqualification into the statute, and the court will not add one. Other factors the law requires the judge to consider include the child's preference, the relationship between the proposed guardian and the child, and, ultimately, what is in the child's best interest. Because the district court treated the felony as dispositive and never reached those other factors, that part of its analysis was wrong. On the second point, however, the Supreme Court agreed with the district court. Marques did not serve H.B.'s mother or other close relatives by mail, in person, or by publication, and he did not file the affidavit needed to authorize service by publication. The statute lets a judge excuse normal service in limited circumstances, but Marques did not meet those criteria either. The Supreme Court held that the district court was within its discretion to refuse to overlook the service failures. Because the service problem alone supports the denial, the Supreme Court affirmed the denial of Marques's guardianship petition. But it also instructed the district court to remove the words "with prejudice" from its order, because a denial for failure to serve is not a ruling on the merits. The practical effect is that Marques may file a new petition. If he does, the family court will have to evaluate his suitability using all the relevant statutory factors - not just his criminal record - and then, if it finds him suitable, decide whether the guardianship would be in H.B.'s best interest.

This case is about who can be legally recognized as a parent in Nevada when a child was born through a surrogate arrangement and one of the adults raising the child has no biological connection to the child. Mary Lorenzo and Pierre Gendebien were in a relationship and lived together starting in 2016. In 2017, Gendebien signed a gestational agreement - a contract to have a child through a surrogate (a woman who carries and gives birth to a child for someone else). The child, A.G., was conceived using Gendebien's sperm and an egg from an anonymous donor. The agreement named Gendebien as the only intended parent and left the space for a mother's name blank. Before the child was born, Gendebien obtained a court order establishing himself as the sole parent, and the child's birth certificate left the mother's name blank. A.G. was born in June 2018. Lorenzo and Gendebien raised the child together in their shared home until their relationship ended in November 2021. At first they shared equal time with A.G., but Gendebien gradually reduced Lorenzo's access and eventually cut it off. Lorenzo then went to court in September 2022, asking to be recognized as A.G.'s mother and seeking joint legal and physical custody. She said she and Gendebien had held her out as A.G.'s parent, that they had lived together as a family since before the child's birth, and that Gendebien had promised to add her name to the birth certificate. Gendebien asked the court to throw out her complaint, arguing she had no right to seek parentage because she did not give birth to A.G., did not adopt A.G., was not married to Gendebien, and was not named in the gestational agreement. The district court agreed and dismissed her maternity and custody claims (though it allowed a separate request for nonparent visitation to continue, which was later denied). The Court of Appeals reversed. The court explained that when someone asks a court to dismiss a complaint at the very start of a case, the court must assume the facts the person alleges are true. The question is only whether those alleged facts, if proven, could entitle the person to relief. The court held that Nevada's parentage statutes do not limit motherhood claims only to women who have a biological link to the child. Under NRS 126.231, "any interested party may bring an action to determine the existence of a mother and child relationship," and Nevada's rules about how fatherhood can be presumed apply to motherhood cases "insofar as practicable." The court held that two of the ways a man can be presumed to be a father - living with the child's other natural parent for at least six months before conception and continuing through the period of conception, and receiving the child into his home and openly holding the child out as his own - can apply equally to a woman seeking to be recognized as a mother. Because Lorenzo alleged facts fitting these situations, her case should not have been dismissed at the outset. The court also addressed the surrogacy contract. It held that the contract locked in Gendebien's rights as the intended parent "immediately upon the birth of the child," but did not permanently block other interested people from later trying to establish that they are also a parent - unless they had agreed to be left out. The court noted that the surrogacy statutes were mainly designed to prevent a surrogate from later claiming to be the child's parent, not to forever shut out everyone else. The court sent the case back to the district court with instructions. On remand, the district court must hold an evidentiary hearing. Lorenzo must first prove, by a preponderance of the evidence (meaning more likely than not), that she qualifies as a presumptive parent. If she does, Gendebien then gets the chance to rebut - to overcome - that presumption, but only by clear and convincing evidence (a higher standard). To decide whether rebuttal is appropriate, the court announced a new three-part test looking at how the family was formed, whether the person voluntarily took on parental responsibilities, and whether anyone else is claiming to be the child's second parent. If Lorenzo's presumptive status is not rebutted, she is recognized as a parent and the court moves on to decide custody based on the child's best interest. If it is rebutted, judgment goes to Gendebien.

Allison Schmidt and Erland Alan Fay married in 2019 and have one child. In 2022, Schmidt filed for divorce and asked for things like back child support, reimbursement for the child's health insurance premiums, and costs tied to her pregnancy. The case went to trial, but partway through, the two sides began settling their disputes by stating their agreement out loud "on the record" (meaning the terms were spoken in court and captured in the transcript). Schmidt said she was satisfied with most of the agreement on custody and child support, but at first did not want to give up two claims: reimbursement for her in vitro fertilization (IVF) expenses and past child support for periods when she cared for the child while the couple lived apart. The judge noted the parties were "stuck" and asked Schmidt to decide how she wanted to proceed. Fay then proposed a solution: he said Schmidt had loaned him $6,000 and he had repaid $4,500, and he offered to pay an additional $2,000. When the judge asked if $2,000 would "resolve it," Schmidt agreed. The judge described the $2,000 as a "settlement payment to resolve any other outstanding claims," and Schmidt responded, "[t]hat sounds good." When asked whether she fully agreed with the terms placed on the record, she said "Yes." The district court then wrote up a divorce decree based on that spoken agreement. The decree said Fay would pay Schmidt $2,000, which would serve as "full and final settlement of all past claims for child support arrears, labor/delivery charges, etc." Schmidt later changed course. She asked the court for relief from the decree, requesting a new trial on the financial issues and that the decree be corrected to match what she believed was actually agreed. Separately, several months after the decree, she received a Facebook friend request from the judge. On advice from the State Bar, she disclosed the friend request to Fay and tried to hire a lawyer for the upcoming hearing but could not find one on short notice. She asked the court to delay the hearing so she could obtain counsel. The court denied that emergency request and, after a hearing, also denied her motion for a new trial. On appeal, the Court of Appeals examined the trial transcript and concluded there was solid evidence that Schmidt had agreed the $2,000 payment resolved all of her remaining financial claims and that the decree accurately reflected that agreement. The court noted she never objected when the judge stated the payment would settle the outstanding claims, and she confirmed she was in full agreement. The court also rejected her argument about being denied a delay to hire a lawyer, finding she did not show she was harmed or that the result would have been different — particularly because the friend request happened months after the decree was already entered. To the extent she suggested the judge was biased, the court found she did not show the alleged bias came from outside the case or reflected the kind of deep hostility that would prevent a fair judgment. The court affirmed.

Jared and Randell Cleland were married and share three minor children; both initially lived in Nevada. After the marriage broke down, Jared moved to Hurricane, Utah, and took the two youngest children with him. Randell filed for divorce and asked for primary physical custody of the two youngest children, arguing the oldest child was not part of the case because Jared was not that child's biological father. Jared countered that he had adopted the oldest child and asked for primary physical custody of the children so they could live with him in Utah. While the case was pending, a temporary order let Jared keep primary physical custody of the two youngest children, with Randell having weekend parenting time. At an evidentiary hearing, the two parents told very different stories. Randell testified she had agreed only that the children could stay with Jared for most of the summer and always intended for them to live and attend school in Nevada. Jared testified that Randell had orally agreed the two youngest children could live with him and attend school in Utah, and he pointed to Facebook Messenger exchanges as proof. Randell said those messages concerned only the logistics of summer parenting time. She acknowledged deleting some messages but said they were messages she inadvertently sent while her phone was in her pocket or that contained typos. Jared acknowledged that after being served with the divorce complaint, he was upset by Randell's custody request and, out of frustration, did not bring the children to Las Vegas for her previously agreed parenting time. The district court sided with Randell. It found that Jared was the legal father of all three children because he had signed voluntary acknowledgments of paternity, but it denied his relocation request, found the parties' messages were ambiguous and did not show Randell had consented to the move, awarded the parties joint legal custody, and gave Randell primary physical custody. Jared then asked the court to reconsider, arguing the deleted messages should have triggered a legal presumption that they were harmful to Randell's case - in other words, that the court should have assumed the deleted messages showed she consented to the move. The court denied reconsideration, finding that both parties had testified about the messages and that any information in them had little bearing on its relocation decision. The Nevada Court of Appeals affirmed. It explained that when no custody order exists, one parent may not move a child out of state over the other parent's objection without a court order allowing the move. The appellate court held that the district court's detailed findings on the relocation factors and the children's best interests were supported by substantial evidence - among them, that Jared moved without adequate housing for the children, that he used the relocation to frustrate Randell's parenting time, and that separating the youngest children from their older sibling caused them emotional pain. On the deleted messages, the court explained that a parent seeking the adverse-evidence presumption must show the evidence was destroyed with intent to harm, and Jared failed to meet that burden. Because appellate courts do not reweigh evidence or second-guess credibility findings, the Court of Appeals found no abuse of discretion and affirmed.

This case concerns who is legally recognized as the father of a child, A.A., born in 2011, and how custody of A.A. should be divided. Three adults are involved. Rosie is the child's mother. Henry was Rosie's on-and-off partner; when A.A. was born, Henry and Rosie signed a Voluntary Acknowledgment of Paternity (a sworn statement declaring Henry to be the father), and Henry's name went on the birth certificate. Ignacio was also Rosie's on-and-off partner during the same period and is the biological father of Rosie's second child, J.A., based on earlier paternity testing. For years, Ignacio suspected he might also be A.A.'s biological father. Rosie and Henry told him he was not, and Henry once showed Ignacio a screenshot of a DNA test purporting to confirm Henry's paternity. Ignacio thought the test looked suspicious and obtained his own DNA tests, which showed he was A.A.'s biological father. Rosie continued to deny him regular contact with A.A. Ignacio sued for a paternity determination and custody. The district court initially ruled against him, saying his challenge came too late. Ignacio appealed, the Nevada Supreme Court reversed, and on remand the district court ordered formal DNA testing. The testing confirmed Ignacio is A.A.'s biological father. The district court then declared Ignacio the legal father, ordered the birth certificate amended, and awarded Ignacio and Rosie joint physical custody. Henry was reduced to a "third party" who could request visitation similar to a grandparent. Rosie and Henry appealed to the Nevada Supreme Court. They argued biology should not automatically determine legal fatherhood once a child is past age three, that the birth certificate should control, and that the trial court failed to properly analyze A.A.'s best interest before ordering joint custody. The Nevada Supreme Court rejected each argument and affirmed. It held that under Nevada's Parentage Act, a DNA test showing 99% or higher probability of paternity creates a "conclusive presumption" of fatherhood - meaning it cannot be overcome by other evidence. Because Ignacio's test met that threshold, he is A.A.'s legal father, with all the rights that come with being a parent. The court explained that an older Nevada decision, Love v. Love, which had treated DNA evidence as just one factor, no longer controls because the Legislature changed the statute in 2007 to make DNA results conclusive. The court also explained that the birth-certificate statute Rosie and Henry relied on does not make the certificate dispositive when paternity is contested and the listed father was never married to the mother. On custody, the court held that the trial judge did not have to apply the legal test for modifying an existing custody order, because there was no prior custody order for A.A. Nevada law presumes joint physical custody is in a child's best interest, and the trial court found that Rosie and Henry had intentionally kept Ignacio away from A.A. for years - a circumstance that statutorily favors joint custody. The Supreme Court found no abuse of discretion.

Lillian Hargrove and Thomas Ward had a son together but were never married and never went to court to set up a formal child support order while their son was growing up. After the son turned 18, Hargrove sued Ward, asking the court to order Ward to pay her back child support for the years she had primary care of the child. She made two arguments: (1) Ward had promised in writing (through text messages and a course of conduct) to pay $400 per month, and Nevada law makes such written promises enforceable; and (2) even without an agreement, Nevada law lets a parent who had physical custody recover up to four years of past child support from the other parent. The trial judge said he did not have the power to award child support after the child had already become an adult, and so he denied Hargrove's request. Hargrove appealed. The Nevada Supreme Court split the issues. On the written-promise theory, the Court agreed with the trial judge that Ward never made the kind of clear, specific written promise that the statute requires. Text messages saying things like "Yes" to a single deposit request, or promises to send money "as soon as i can," were either too narrow or too vague to count as an enforceable promise to pay ongoing monthly support. So that part of the trial court's ruling was affirmed. On the retroactive child support theory, however, the Court reversed. It held for the first time that a parent can sue for retroactive (back) child support even after the child has reached the age of majority, as long as the lawsuit is filed within three years of the child's 18th birthday - the same window Nevada gives for filing a paternity action. The recovery is still capped at four years of support immediately before the lawsuit was filed. Because Hargrove filed her case roughly 15 months after her son turned 18, her request was timely, and the trial judge was wrong to say he lacked authority to consider it. The case was sent back to the district court for further proceedings.

This case involves a dispute over the adoption of a child, G.P., among the child's relatives. Before G.P. was born, the birth mother asked the child's step-great-grandmother and great-grandfather, Katherine and Michael, to take temporary guardianship. They agreed and obtained temporary guardianship from a Washoe County court. The child's grandparents, Angela and Randall, then filed their own competing petition for guardianship in the same court. While the guardianship dispute was pending, the birth parents signed written consents to terminate their parental rights and to allow Katherine and Michael to adopt G.P. Katherine and Michael then filed an adoption petition in Clark County, where they live. The Clark County court, unaware that a guardianship case was pending in Washoe County, granted the adoption. When the grandparents Angela and Randall learned of the adoption, they asked the Clark County court to set it aside under a procedural rule (NRCP 60(b)) that lets courts undo judgments in cases of fraud, misrepresentation, or misconduct. They argued the great-grandparents had hidden the existence of the Washoe County guardianship case. The Clark County judge agreed and set aside the adoption. The Nevada Supreme Court reversed. The central question was whether the grandparents had "standing" — that is, the legal right — to ask the court to undo the adoption at all, given that they were not parties to the adoption case. The Supreme Court explained that only parties to a case, people in close legal privity with parties, or nonparties whose own legal rights are directly affected by the judgment can file an NRCP 60(b) motion to undo it. The Court concluded that being a grandparent, by itself, does not give someone a legal interest in a grandchild's adoption sufficient to challenge it. Nevada's adoption statutes do not list grandparents among those entitled to notice or to object, and grandparents generally do not have a constitutional right to intervene in an adoption absent something extra, like a pre-existing court-ordered visitation right. The Court also held that simply having filed a guardianship petition that had not yet been decided created only a "prospective" interest — a possible future interest — which is not enough to confer standing to attack an adoption decree. Because Angela and Randall were not parties to the adoption, were not in privity with a party, and had no legal interest that was directly affected by the adoption decree, the Supreme Court held the district court should not have entertained their motion. The adoption stands.

Dana and Manuela Hoodenpyle traveled to Las Vegas in May 2004 for a short vacation to get married. After the trip, they returned to Virginia to live. Nearly twenty years later, in April 2024, Dana filed for divorce in Nevada. He initially obtained a clerk's entry of default (a preliminary step a plaintiff can take when the other side does not respond in time), but Manuela asked the court to set that default aside, arguing that neither party lived in Nevada. The district court set aside the default and told Manuela to file an answer or other pleadings. Manuela then answered, filed a counterclaim, and separately moved to dismiss the case, arguing that the Nevada court had no power over her personally because she had never lived in Nevada and had not conducted business or transactions there. This concept is called "personal jurisdiction" - a court's authority to make decisions that legally bind a particular person. Dana disagreed. He argued that Manuela had enough connection to Nevada because the couple married in Nevada, because she had hired an attorney and participated in the case, and because a family-run company, MMP-USA LLC (a Virginia company), sold parts in many states, including Nevada. He attached various business documents to support this claim. The district court found that it did not have personal jurisdiction over Manuela. It noted that although the couple married in Nevada in 2004, Manuela had never lived in Nevada, and the parties' business was formed in Virginia. Because Dana himself was present in Nevada, the court granted what it called a "status divorce" - meaning it ended the marriage itself - but ruled that the couple would have to sort out their property in a court that had jurisdiction over their property. On appeal, the Court of Appeals agreed with the district court. It explained that a court can only exercise power over an out-of-state person if that person has enough meaningful connections to the state. A one-week wedding trip two decades earlier was not enough, and the business documents Dana submitted did not show that Manuela herself was personally involved in any Nevada activities. The court also rejected Dana's argument that a hearing was required before deciding the issue, explaining that a judge may decide a fully briefed personal-jurisdiction motion without holding a hearing. The court affirmed the district court's decision.

This is a very short procedural order, not a decision about the merits of any underlying family-law dispute. Edward Foster filed an appeal against Amy Steele, who was formerly known as Amy Foster. When someone starts an appeal, the court requires a filing fee to be paid. According to the order, Foster's appeal was placed on the court's docket on May 12, 2026, but the required filing fee was not paid. That same day, the court sent Foster a notice telling him to either pay the fee or show that he qualified to proceed without paying it, and gave him 14 days to do so. The notice warned that if he did not comply, the appeal would be dismissed. Because the fee still had not been paid, the court entered another order on July 6, 2026, again directing Foster to pay the filing fee within 14 days and again warning that failure to comply would result in dismissal. The order states that, as of the date it was issued, Foster had still not paid the filing fee. As a result, the court dismissed the appeal. The order does not discuss the facts of the family dispute or reach any conclusion about who should win it.

This case involves a divorce. James Samuel Short, who was representing himself without a lawyer (referred to in court as "pro se"), tried to appeal the divorce decree - the final court order that legally ends a marriage - that a lower court in Nye County had issued. When someone appeals, the higher court requires certain paperwork to move the case forward. Here, the Supreme Court of Nevada told Short on June 26, 2026, to file two things: a transcript request form (paperwork about obtaining the written record of what was said in the lower court) within 14 days, and a docketing statement (a form giving basic information about the appeal) within 21 days. Short did not file them. The court then gave Short a second chance. On July 24, 2026, it ordered him to file the transcript request form (or a certificate saying no transcript was requested) and the docketing statement by July 31, 2026. The court warned him that if he did not comply on time, his appeal could be dismissed. Short still did not file the documents. Because Short never filed the required paperwork, the court concluded he had abandoned - given up on - his appeal, and it dismissed the case. The court did not decide anything about whether the divorce decree itself was correct or fair; it ended the appeal on procedural grounds only. The order also addressed the other party, Love A Rydes-Short. She had asked the court to let her dismiss her attorney, Ronald Brilliant, and represent herself. The court granted that request and directed the clerk to remove Mr. Brilliant as her lawyer of record.

Hakeem Khalifah appealed on his own behalf (without a lawyer, which is what "pro se" means) after a district court judge in Clark County denied his requests to reconsider and undo two earlier rulings in a child custody matter. One of those earlier rulings found him in contempt of court and gave the other party, Monique Hollings, temporary custody. The other ruling dealt with certifying that the district court would take up custody issues on a remand. Before deciding anything about the merits of the dispute, the Supreme Court of Nevada looked at whether it even had the authority to hear the appeal at all. Courts can only review certain kinds of orders on appeal; if a particular type of order is not one the law allows to be appealed, the appellate court has no power ("jurisdiction") to consider it. The court explained that while orders denying motions to reconsider or vacate can sometimes be appealed, that is only true when the underlying order those motions attacked was itself something that could be appealed. Here, the court concluded the underlying orders were not appealable. A contempt order that is connected to (ancillary to) another proceeding cannot be appealed on its own, and an order granting temporary custody is not the kind of custody decision that can be appealed. Under the applicable rule, custody appeals are allowed only from orders that finally resolve custody issues, and a temporary custody order does not do that. Because the underlying orders could not be appealed, the denial of the motions to reconsider and vacate them could not be appealed either. Having found it lacked jurisdiction, the court dismissed the appeal without reaching the substance of the custody dispute.

This is a short procedural order, not a decision about who wins the underlying family-law dispute. Tina Leah Rohmiller tried to appeal a district court order that had done several things: it put off (deferred) a decision on whether to formally label her a "vexatious litigant" - a designation courts use for parties who repeatedly file baseless papers; it announced that her future filings would get "heightened scrutiny"; it canceled upcoming hearings; it required her to pay $25.00 for each motion she files; and it scolded her for what the district court called "serial nonsensical filings." The Nevada Supreme Court did not weigh in on whether any of that was fair or proper. Instead, it concluded it had no power - no jurisdiction - to hear the appeal at all. In Nevada, a party can only appeal an order if some statute or court rule specifically authorizes an appeal from that kind of order. The court found that no statute or rule allows an appeal from an order that merely defers a ruling, applies heightened scrutiny to future filings, vacates hearings, imposes a standard motion fee, or admonishes a party. Because the order was not appealable, the court dismissed the appeal without addressing its merits.