Nevada family-law case summaries

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.