Nevada family-law case summaries

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.