Nevada family-law case summaries

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.

Ricky DeNoto and Alisha Babbe Hilton, who were never married, share one child, T.D., born in 2017. After both moved to Nevada, they split parenting time evenly, one week on and one week off. Although both parents stayed involved, Hilton generally handled T.D.'s medical care, insurance, appointments, and school matters, and DeNoto usually deferred to her on those issues. In early 2024, Hilton took a temporary surgical-technologist job in Hawaii. The parents, representing themselves, signed a written "Permission to Travel" agreement letting T.D. stay in Hawaii from June 6, 2024, until sometime between July 8 and July 13, 2024. According to the opinion, Hilton did not present the trip as a permanent move, though she shipped her car to Hawaii before leaving. As the return date approached, DeNoto asked for travel details; Hilton first responded, then became evasive, and then stopped communicating. T.D. never came back and has remained in Hawaii. That August, DeNoto learned from T.D. that Hilton had enrolled him in a Hawaii school without DeNoto's knowledge or consent. The next month, T.D. was struck by a vehicle in the front yard of Hilton's Hawaii home. He suffered serious injuries, was placed in a medically induced coma for three days, hospitalized until late October, treated in the ICU, and underwent major surgery. By the time of trial, T.D. had undergone multiple surgeries, resumed some activity, and been cleared to travel, but still needed ongoing care, including one more surgery. DeNoto filed a paternity case in October 2024, and Hilton answered and counterclaimed. There were no prior custody or support orders. At trial, the district court decided Nevada had jurisdiction because T.D. had lived in Nevada for years before the June 2024 departure and because DeNoto filed within months of that departure. The parents agreed to share legal custody (the right to make major decisions), and the court entered detailed rules requiring them to consult on decisions, share medical and school information, and support T.D.'s relationship with the other parent. The contested question was physical custody — where T.D. would primarily live. The court worked through the statutory "best interest of the child" factors. It found most factors neutral. It found two factors favored Hilton: the parents' ability to cooperate to meet the child's needs (because Hilton historically handled medical, insurance, and school matters and had supported T.D. financially in Hawaii), and the child's physical, developmental, and emotional needs (because of his serious injuries, ongoing medical and therapy needs, school accommodations, and Hilton's ability to keep him on medical, dental, and vision insurance). The court awarded Hilton primary physical custody in Hawaii, gave DeNoto parenting time over school breaks and long weekends plus phone contact, and set child support and related financial terms. On appeal, DeNoto argued the court mishandled several best-interest factors, downplayed Hilton's failure to return T.D. and her unilateral school enrollment, failed to resolve conflicting testimony with credibility findings, and reached conclusions unsupported by the evidence. The Court of Appeals explained that it reviews custody decisions only for "abuse of discretion" — a deferential standard that does not allow the appeals court to re-weigh evidence or re-judge witness credibility. The court agreed with DeNoto on one point: the district court's finding that one factor (whether a parent would allow the child a continuing relationship with the other parent) was "neutral" seemed inconsistent with the trial court's own findings that Hilton had "reneged on the agreement," become evasive, gone "radio silence," and enrolled T.D. in school without consent. But the appeals court concluded the trial court did not ignore that conduct — it acknowledged the conduct and weighed it against other evidence, such as the parents' long history of co-parenting, DeNoto's phone access, and his extended visits. The appeals court held that even if that factor was weighed improperly, it would not change the result, because DeNoto did not meaningfully dispute the finding about T.D.'s serious medical and educational needs, which strongly supported placing him with Hilton. Because the district court considered the required factors, made findings adequate for review, and reached a decision supported by evidence a reasonable person could accept, the Court of Appeals affirmed.

This case involves a baby, A.R., who was removed from her parents in 2022 because of neglect and abuse. The Clark County Department of Family Services (DFS) initially placed her with her paternal aunt, Mary. Over time, A.R. also began spending weekends with her maternal grandmother, Ericka. Both relatives loved A.R., wanted to adopt her, and were considered fit caregivers. After the parents' rights were terminated by the court, the district court had to decide where A.R. should live permanently. Both the aunt and the grandmother were good options, and the district court found them "equally situated" in most respects. To break the tie, the court considered DFS's recommendation. DFS preferred the aunt's home because A.R. had developed a close, sibling-like bond with her cousin (the aunt's child), and DFS believed keeping that bond intact was best for A.R. The court placed A.R. with the aunt for adoption, while preserving the grandmother's role through a Post Adoptive Contact Agreement giving her alternating weekend visits and two weeks of summer vacation each year. The grandmother asked the Nevada Supreme Court to step in through a writ of mandamus - a court order directing a lower court to perform a duty required by law. She argued the district court placed too much weight on DFS's recommendation, did not make sufficient findings, did not hear enough evidence, and improperly favored a "nuclear family" structure. The Supreme Court rejected those arguments and denied the petition. It explained that, after parental rights are terminated, a different statute (NRS 128.110) governs placement, and that statute gives the agency holding the child's custody discretion in deciding placement. The district court is not bound by the agency's preference, but it must consider it as part of figuring out what is in the child's best interest, which always remains the paramount concern. Here, the district court did exactly that: it acknowledged it could override DFS, but found DFS's reasoning - protecting A.R.'s bond with her cousin - persuasive. The Supreme Court also concluded that the district court's findings were sufficient and that its decision was not based on a generic preference for "traditional" families but on the specific facts of A.R.'s relationships. Some of the grandmother's other arguments were treated as waived because she did not raise them in the district court.

Tiffany and James Sullivan divorced in 2012 and agreed to share joint legal and physical custody of their daughter, G.S. Over the following decade, James filed several motions asking the court to give him primary physical custody. The appeal in this case arises from his third such motion, filed in April 2022. James pointed to three alleged changes: an October 2021 domestic violence incident between Tiffany and her then-boyfriend, Martin (who was later convicted of felony aggravated stalking for violating protective orders Tiffany obtained against him); a February 2022 conversation James recorded with G.S., in which the child said Tiffany often left her alone to care for her younger half-sister, did not prepare her meals, and that she would prefer to live with James; and concerns that G.S. was underweight and possibly not eating properly. Before the trial (called an "evidentiary hearing"), the court ordered that G.S. be interviewed by a neutral professional. The parties settled on Dr. Stephanie Holland, who interviewed the child and sent her report to the court. But Tiffany did not formally list Dr. Holland as a witness until after the deadline the parties had agreed to. On the first day of the hearing, James raised no objection—in fact, he agreed to take witnesses out of order so Dr. Holland could testify the next morning. The next morning, however, James objected that Tiffany had disclosed Dr. Holland too late, and the district court agreed, refusing to let Dr. Holland testify or her report come into evidence. After hearing testimony from Martin, a former babysitter, G.S.'s pediatrician, James, and Tiffany, the district court awarded James primary physical custody, finding that five of the statutory "best interest of the child" factors favored James and none favored Tiffany. The Court of Appeals concluded the district court made mistakes—but not mistakes big enough to change the outcome. First, it held that James waited too long to object to Dr. Holland's testimony. Because he participated in the interview process, knew about the late disclosure a month before the hearing, and even agreed on the first day of the hearing to let Dr. Holland testify out of order, he could not spring the objection at the last minute. The court also emphasized that Nevada public policy strongly favors letting courts consider all evidence bearing on a child's best interest; by excluding the court-appointed interviewer's testimony and report, the district court "hindered its own inquiry into G.S.'s best interest" and, in effect, sanctioned the child for her mother's procedural misstep. Second, the appellate court found that two of the district court's best-interest findings were not backed by substantial evidence: the finding that the parents' "ability to cooperate" factor was neutral (the record showed James was the less cooperative co-parent, including never giving Tiffany the number to G.S.'s phone at his house), and the finding that the "relationship with each parent" factor favored James, which rested on the recorded conversation without the expert analysis Dr. Holland would have provided. Even so, the Court of Appeals affirmed. Under Nevada law, an error justifies reversal only if it likely would have changed the result. Here, the remaining best-interest findings were supported by substantial evidence—particularly that James consistently provided G.S. three meals a day, got her to school on time, and offered a stable home—and Tiffany did not include Dr. Holland's report in the appellate record, which limited the court's ability to assess what difference it might have made. Finally, the court rejected Tiffany's claim of judicial bias: judges are presumed impartial, and rulings formed from what a judge learns during the case itself are not evidence of bias.

Christopher Fisher and Elia Cobian were never married but were in an on-again-off-again relationship, and their daughter, L.F., was born in May 2019. The relationship ended after a physical altercation in April 2020 in which each parent accused the other of being the aggressor; no arrests or charges resulted, but Elia obtained a temporary protection order from the Elko Justice Court that gave her sole legal and physical custody of L.F. Both parents then went to district court seeking custody. A court-ordered custody evaluator recommended that the parents share joint legal and joint physical custody, and the case proceeded to a two-day evidentiary hearing in February 2022. At that hearing, the court heard testimony about Christopher's 2018 DUI conviction, his ongoing alcohol use, his partner's alcohol use, his refusal to give Elia his address, his estranged relationships with children from a previous relationship, health issues L.F. experienced, and his failures to tell Elia when he traveled out of town with the child. Christopher also acknowledged an incident involving a daughter from a previous relationship in which the Utah Division of Child and Family Services substantiated an abuse and neglect charge against him. Nevada law requires courts deciding custody to weigh a list of "best interest of the child" factors. The district court found that eight of the twelve factors favored Elia and that the rest were neutral or inapplicable, so it awarded her primary physical custody, with Christopher receiving parenting time from Sunday morning through Tuesday afternoon every other week. After hiring a new lawyer, Christopher asked for a new trial, arguing his trial counsel failed to present any evidence on his behalf; the district court denied that motion, and he appealed. The Nevada Court of Appeals affirmed. Christopher argued that the district court had to first work through the statutes expressing a preference for joint physical custody before analyzing the best-interest factors. The appellate court explained that the sole consideration in a custody decision is the best interest of the child, and that even though the district court did not explicitly cite those preference statutes, it recognized the preference for joint custody but specifically found that "joint custody was not appropriate" under the totality of the circumstances. The court of appeals also declined to reweigh the evidence or the district court's credibility determinations, concluding that substantial evidence - evidence a reasonable person could accept as adequate - supported the ruling. As for Christopher's complaints about the court considering events before L.F.'s birth and allegations he said were not properly noticed, the appellate court held those objections were waived because he did not raise them in the trial court. It added that a district court may consider a parent's past conduct when determining a child's best interest, and that any error was harmless because the district court made numerous findings about the current custodial circumstances. Finally, the court noted one clerical mistake: page 12 of the district court's order erroneously refers to awarding Christopher primary physical custody, and it sent the case back solely to fix that error.

Brittany Sheehan and Justin Manty have one child together, T.S. Before this case began, there was no court order in place about who had custody. Brittany filed a case in Nevada asking a court to establish custody, parenting time, and child support. Justin responded by filing his own custody case in California and asking the Nevada court to dismiss Brittany's case for lack of jurisdiction (the court's authority to decide the matter). According to the opinion, Brittany then went to California, took T.S. out of her school, and brought her to Nevada. California criminal charges were filed against Brittany over that incident. After a hearing, the Nevada district court ordered Brittany to return T.S. to Justin and dismissed the Nevada case, finding that California was the more convenient place to handle the dispute because most of the evidence and witnesses were there. On appeal, Brittany made several arguments. First, she said the judge, Dedree Butler, showed bias by saying at the hearing that she "d[id]n't know if [T.S. is] safe right now" and that "for all [she] kn[e]w [T.S. is] . . . somewhere in a basement tied up." The Court of Appeals explained that judges are presumed to be unbiased, and it read the judge's comments—though it described them as "arguably hyperbolic"—as simply stating that the judge did not know where the child was because Brittany would not say. The court found no proof that the judge's rulings were driven by bias. Second, Brittany argued the court should have held an evidentiary hearing on jurisdiction. The court rejected this because she did not cite supporting legal authority, did not explain why such a hearing was needed, and did not identify any disputed facts the court would have had to resolve. Third, Brittany argued the court improperly relied on hearsay (out-of-court statements) from Justin. The court said that even if she were right, it would not change the outcome, because she never disputed the core reason for dismissal—that California was the more convenient forum. She also never addressed the specific statute the court used to dismiss the case. Finally, Brittany argued the court was wrong to order the child returned to Justin without weighing the "best interest of the child" factors. The court explained that it acted under its temporary emergency jurisdiction, pointing to how T.S. had been removed from California (with Brittany criminally charged and subject to an active arrest warrant) and to Brittany's refusal to reveal where the child was, which left the court unsure the child was safe. The court found those oral findings sufficient. Because none of Brittany's arguments succeeded, the Court of Appeals affirmed.

Alfonso Estrada, an attorney living in Los Angeles, and Ida Arzola, who worked in Las Vegas, had a child together, A.E., born in May 2019. After the relationship ended, both parents went to court seeking primary physical custody - the arrangement where one parent has the child most of the time. Alfonso asked for primary custody; Ida asked for primary custody and also for child support (regular payments from one parent to help cover the child's needs). While the case was pending, the court set up a temporary schedule of joint physical custody, with the parents exchanging the child in Barstow, California, each week. During that temporary period, Alfonso was ordered to pay Ida $1,583 per month in support plus $5,000 in attorney fees, reflecting that Alfonso earns roughly ten times what Ida makes. After a two-day trial, the district court changed course. It awarded primary physical custody to Alfonso, ordered that the child's "habitual residence" stay in Nevada, and directed Ida to pay Alfonso $400 per month in child support. It also ruled that Alfonso, as the "prevailing party," could recover attorney fees, and later ordered Ida to pay Alfonso $40,000 in combined fees and costs. Ida appealed. The Court of Appeals split its decision into three parts. On custody, the court sided with Alfonso and left the custody award in place. It rejected Ida's argument that Alfonso had to meet a higher legal bar to "modify" custody, explaining that because no prior custody order existed, this was an initial determination, not a modification. It rejected her argument that the arrangement should have been called joint custody, noting that the best interest of the child is the main consideration and that percentage of time is only one factor. It rejected her argument that the court should have considered joint custody even though neither parent asked for it, in part because Ida herself never requested joint custody as an alternative. And it found the court's detailed analysis of the best-interest factors was supported by the evidence. On the relocation argument, the court declined to overturn the custody order. Ida had not raised the relocation issue in the lower court, cited no legal authority showing the relocation statute applied to her situation, and did not show that considering relocation factors would have changed the result. On child support, the court agreed with Ida. The district court had said "no adjustment evidence was provided" that would justify lowering Ida's payment - but its own findings described a large income gap (Alfonso earning about $250,000 a year while Ida attended community college), plus travel costs and Ida's limited ability to pay. Because that evidence supported considering a downward adjustment, the Court of Appeals reversed the support order and sent it back for the district court to apply the deviation factors. On attorney fees and costs, the court also agreed with Ida. The district court had awarded fees based only on Alfonso being the "prevailing party," without citing a legal basis, without making required findings, and without addressing the income disparity between the parties. The statutes Alfonso relied on did not fit the situation, and the order lumped fees and costs together without saying how much was which, making it impossible to review. The Court of Appeals reversed that award and sent it back as well.

This case is about a custody, child-support, and attorney-fee dispute between two parents of a young child. Alfonso Estrada is an attorney living in Los Angeles who met Ida Arzola in 2017 at a Las Vegas strip club where she worked as a dancer. They had a relationship, and a child, A.E., was born in May 2019. After the birth, the relationship became contentious. Alfonso asked the court for primary physical custody (meaning the child would live with him most of the time). Ida asked for primary physical custody too, and she also asked for child support. The parents agreed to share legal custody (decision-making about the child). While the case was pending, the court set up a temporary arrangement where they shared physical custody, exchanging the child each week in Barstow, California, and temporarily ordered Alfonso to pay Ida $1,583 per month in child support plus $5,000 in attorney fees. By this time, Ida was working as a food server earning about one-tenth of Alfonso's salary and had started nursing school. After a two-day trial, the district court awarded primary physical custody to Alfonso on a three-week-on, two-week-off schedule, with two extra weeks for Alfonso during the year. The court kept Nevada as the child's official home ("habitual residence") and set a status check before the child starts school. It also ordered Ida to pay Alfonso $400 per month in child support and awarded Alfonso attorney fees, saying only that he was the "prevailing party." Alfonso later asked for $48,217 in fees and $2,138.77 in costs; the court ultimately ordered Ida to pay a combined $40,000 in fees and costs, without saying how much was fees and how much was costs. Ida appealed. The Court of Appeals reached three main conclusions. First, on custody, the court upheld the district court's decision to give Alfonso primary physical custody. The court rejected Ida's arguments: that this was really a modification of an existing custody arrangement (it was not, because there had been no prior custody determination); that a case called *Bluestein* required treating the arrangement as joint custody (the court explained percentage of time is just one consideration and the child's best interest controls); that the court had to consider joint custody even though neither parent asked for it (Ida had not requested it and could not now complain of an error she helped cause); and that the court misapplied the best-interest factors (the court found the district court's detailed findings were supported by the evidence). Second, on the claim that the court improperly "relocated" the child to California, the court found Ida had not raised this argument below, had not cited supporting authority, and had not shown that a relocation analysis would have changed the outcome. Third, on child support and attorney fees, the court sided with Ida. On child support, the court held the district court should have considered whether to reduce Ida's payment given the large income gap between the parties, and it reversed and sent that issue back. On attorney fees, the court held the award could not stand because the district court gave no legal basis for it and failed to make required findings — including about the income disparity — and because Alfonso's own filings were deficient. The court reversed and remanded the fee-and-cost order.

Desmon Brandes and Lacey Pictum (now Lacey Krynzel) were never married but have one child together, born in 2007. In 2011, they agreed to share joint legal custody, with Lacey having primary physical custody and Desmon paying $400 per month in child support. Because Lacey had struggled with opioid addiction, their agreement said Desmon would become the primary physical custodian if Lacey relapsed. According to the opinion, Lacey did relapse, and Desmon served as the child's primary physical custodian from late 2011 until 2015, while Lacey had supervised parenting time. In 2015, Lacey married and says she has been clean from opioids since that year. After that, the child spent alternating weekends and summer time with Lacey. This arrangement continued until March 2020, when schools closed due to the COVID-19 pandemic and the parties agreed the child would stay with Lacey on her summer schedule until school resumed. Also in March 2020, Lacey applied for welfare benefits, which prompted the district attorney's office to open a case to enforce Desmon's child support obligation and collect back payments. Desmon opposed that effort and filed his own motion, saying he had actually been the primary custodian for years and asking the court to change the custody order. He argued that circumstances had substantially changed and that, since Lacey appeared to have been sober for years, joint physical custody would be best for the child. During the case, Desmon submitted text messages and a video from the child (then 14) expressing worry that Lacey was using drugs again, describing erratic driving and "zone out" episodes. The court ordered Lacey to take a drug test, which showed trace amounts of THC but was negative for opioids and other substances. The court then set an evidentiary hearing and told the parties to keep their current schedule for the time being. The child later told Lacey she preferred to live with Desmon until Lacey "got better," and with Lacey's permission lived with Desmon for the five months before the hearing. Because of this, Desmon changed his request and asked for primary physical custody. After a hearing where both parents testified, the district court issued a 21-page order. It found that the 2011 order should be modified and awarded the parents joint physical custody with a 50/50 split. Desmon appealed, agreeing that the old order should be changed but arguing the court was wrong to order joint custody rather than give him primary custody, given the family's history, Lacey's history of substance abuse, and the child's stated preference. The Court of Appeals reversed. It explained that when a court decides custody, it must not only make findings about the "best interest" factors but must also explain how those findings led to the final custody decision. Here, the court noted, the district court did make detailed findings — including that Lacey has a history of opioid addiction, that the child wanted to live with Desmon, that three factors favored Desmon, and that no factors favored Lacey — but never explained how those findings led to its conclusion that joint custody was best. Because the district court did not connect its findings to its ultimate decision, the Court of Appeals concluded it abused its discretion, reversed the order, and sent the case back so the district court could provide that missing explanation.

Ken Nguyen and Robert Boynes were a same-sex couple who dated from November 2009 to May 2013. During the relationship, they decided to adopt a child together and went to Catholic Charities of Southern Nevada. At the time, Catholic Charities did not allow same-sex couples to adopt jointly, so according to Rob, the plan was for Ken to adopt first and Rob to adopt afterward as a second parent. Both men took part in the entire adoption process - background checks, classes, post-placement visits - and Rob even drafted the "birth mother letter" that helped them be selected. A child was placed with Ken in February 2013, and both men were there to receive the newborn. After the placement, the child spent most nights at Rob's house, Rob took the child to most doctor's visits, supplied most of the baby gear, and was listed as a father on the child's baptism certificate. The child's middle name is Rob's surname. But the men's relationship ended in May 2013. When Rob asked Ken to put him on the birth certificate, Ken refused. Ken finalized his own adoption alone in October 2013 and refused to let Rob complete a second-parent adoption. Rob then sued, asking the court to recognize him as a parent and to give him custody. The district court ruled for Rob, and Ken appealed. The Nevada Supreme Court affirmed. The Court applied a doctrine called "equitable adoption," which allows a court to enforce an adoption agreement when one person promised to adopt, the other relied on that promise, and a child would be harmed if the promise were broken. The Court had recognized this doctrine in a 1987 case (Frye v. Frye) and had declined to extend it in two later cases where the dispute was really about whether someone was the biological parent. Here, the Court said this case was different: neither Ken nor Rob is biologically related to the child, and the question was whether the two men had agreed to adopt together. The Court found substantial evidence that they had agreed, that Rob relied on Ken's promise, and that the child would be harmed by Rob's removal from his life. The Court also rejected Ken's claim that the district court treated him differently because he and Rob were a same-sex couple. The Court said child custody decisions are made case by case, and nothing in the record showed the result turned on the parties' sexual orientation. Finally, the Court affirmed the joint custody order. Ken had argued Rob was a "stalker" who sent harassing emails, which would trigger a presumption against giving custody to a perpetrator of domestic violence. The district court found only a single forwarded email tied to Rob, which it concluded was not enough to show "obsessed stalking behavior." Ken also accused Rob of destroying his computer to hide evidence; the district court found the proof inconclusive. The Supreme Court held substantial evidence supported those findings. Three justices - Justice Stiglich, Chief Justice Cherry, and Justice Hardesty - concurred. They would have reached the same outcome under Nevada's Parentage Act rather than under equitable adoption, relying on the Court's earlier decision in St. Mary v. Damon, which recognized that paternity statutes can apply in same-sex parentage cases.