Nevada family-law case summaries

Michelle Iranpour and Mark Winningham married in 2013 and had three minor children. In 2021, Iranpour filed for divorce. Over the course of the case, the district court held several hearings addressing contested issues including child custody, child support, spousal support, and how to divide the couple's shared property and debts. In July 2022, Iranpour's lawyer asked to postpone a scheduled trial in order to gather more information about alleged "marital waste" (wasting of shared assets) by Winningham. The court granted that request and rescheduled the trial for October 2022. Three days before the new trial date, Iranpour's lawyer again asked to postpone the trial, and the court set that request to be heard on the same day as the trial itself. According to the opinion, Iranpour's lawyer then did not show up either for the hearing on the postponement request or for the trial. Because the lawyer did not appear and did not show a good reason to delay, the district court declined to take any new evidence and said it would decide the divorce based on the briefs, arguments, and evidence already presented in the earlier hearings. On October 13, 2022, the court entered the divorce decree with its findings on custody, support, and property. On appeal, Iranpour made a single main argument: that the court held a trial without her lawyer present despite her requests. The Court of Appeals found that this description did not match the record. The transcripts Iranpour herself submitted showed the court did not hold a trial in her lawyer's absence; instead, because her counsel failed to appear and gave no good cause to postpone, the court resolved the case on the materials already in the record. The appeals court concluded that Iranpour never explained how the court's actions actually harmed her or pointed to any specific mistake in the decree, so she failed to present a developed legal argument the court could consider. The court also noted that, to the extent she was challenging the district court's earlier rulings, she had not included the necessary orders and transcripts in her appeal record. Under Nevada law, when parts of the record are missing, the appeals court assumes those missing materials support the lower court's decision. For these reasons, the court affirmed the divorce decree.