Nevada family-law case summaries

This is a case about a parent's attempt to change a child custody arrangement. Tina Leah Rohmiller asked the district court to modify the custody order in her case, but on December 7, 2025, the district court said no. She then filed several follow-up motions asking the court to reconsider, rehear, or undo that decision. While her appeal was pending, the Supreme Court of Nevada told the lower court (on April 27, 2026) to first resolve those pending follow-up motions and paused the briefing schedule - the written arguments that each side files. The district court then denied those follow-up motions on May 15, 2026. In this order, the court cleaned up and organized the multiple related appeals Rohmiller had filed. It found that the appeal in one docket (No. 92490) was now ready to move forward, so it restarted the briefing schedule. Because a second appeal (No. 92888) came from the same court case and involved the same people, the court combined - "consolidated" - the two appeals so they would be handled together. Rohmiller was given 40 days to file a single opening brief covering the issues in both. The court also ordered the district court clerk to send up a complete copy of the trial court record so the justices can review everything that was filed below. Finally, the court noticed that a third appeal (No. 92643) challenged the very same orders as the appeal in Docket No. 92490. Because it was a duplicate, the court dismissed the appeal in Docket No. 92643, letting the appeal in Docket No. 92490 proceed instead. No decision was made on whether custody should actually be changed; this order deals only with how the appeals will proceed.

Tina Rohmiller tried to appeal an order that she said labeled her a "vexatious litigant" — a designation courts sometimes apply to a person to place limits on their ability to keep filing lawsuits or motions. She represented herself in the appeal. The Nevada Supreme Court did not decide whether she actually is a vexatious litigant or whether any restrictions were fair. Instead, it looked at whether it had the power (called "jurisdiction") to hear the appeal at all, and concluded that it did not. The court gave two reasons. First, it found that there did not appear to be a written order from the district court actually declaring her a vexatious litigant — and appeals generally run from written judgments or orders. Second, and more importantly, the court explained that even if such an order existed, no statute or court rule allows a person to appeal a vexatious-litigant order directly. The court noted that the proper way to ask a higher court to review that kind of order is through a different procedure called a writ — a separate type of request to the court — rather than an ordinary appeal. Because it lacked jurisdiction, the court dismissed the appeal.

Bart and Bonnie Mahoney married in 2000 and had two children. When Bart filed for divorce in 2016, the couple reached an agreement that was merged into the divorce decree. Under the decree, Bonnie received primary physical custody of the children, and Bart agreed to pay child support, cover the children on his medical insurance, pay monthly alimony for five years, pay Bonnie 25% of his annual bonuses (rising to 35% if he failed to give her his annual W-2 tax forms), and pay her attorney fees and costs from the divorce. According to the opinion, Bart did not pay the child support, alimony, or attorney fees, did not pay Bonnie a share of his bonuses, and did not provide his W-2 forms. In May 2019, Bonnie asked the district court to reduce the arrearages (the unpaid amounts) to a judgment—that is, to convert what Bart owed into an enforceable court judgment—with interest and penalties, and to review child support and award her attorney fees. The case wound its way through several hearings. Bart's attorney withdrew in 2020 because Bart had never formally retained him and had stopped communicating. After that, Bart represented himself. The evidentiary hearing was rescheduled several times and ultimately set for December 3, 2020. Notice of that hearing was mailed to Bart's last-known address on file with the court, and Bonnie's attorney also emailed Bart pretrial filings—containing the hearing's date and time—at the same email address Bart had previously used to correspond with that attorney. Bart did not show up at the December 3, 2020, hearing. The district court proceeded with only Bonnie and her attorney present, took evidence including Bart's income and bonus records obtained by subpoena, and granted Bonnie's motion. It found Bart owed child support, alimony, and attorney fees and costs from the divorce, and—because Bart never provided his W-2 forms—awarded Bonnie 35% of his bonuses. It also awarded Bonnie the attorney fees and costs of bringing the motion, setting the amount in January 2021 after Bonnie filed a detailed memorandum of her fees and costs. Bart then moved to set aside the orders under NRCP 60(b), claiming he was never notified of the hearing, but filed his notice of appeal before the district court ruled on that motion. The appeal was still properly before the Court of Appeals under NRAP 4(a)(6), which treats the premature notice as filed on the date the district court denied the set-aside motion. However, because Bart's briefs did not address the denial of that motion, any challenge to it was waived. On appeal, the Court of Appeals rejected all three of Bart's arguments. First, it held that substantial evidence supported the finding that Bart was properly notified of the hearing: notice was mailed to his last-known address (which under the court rules completes service upon mailing), and he also had actual notice via emails from Bonnie's attorney. Bart pointed to nothing in the record—such as a sworn affidavit—showing he did not actually receive notice, and the onus was on him to keep the court updated with his address. Second, the court held that Bart's challenges to the arrearage findings were waived because he never raised those specific arguments in the district court, despite multiple opportunities to do so. Third, the court held that the fee award was not an abuse of discretion: the award was authorized by statute, and the district court made detailed findings under the four-factor test from Brunzell v. Golden Gate Nat'l Bank for evaluating the reasonableness of attorney fees.