Nevada family-law case summaries

Bryce Wolfe and Taylor Mannion (now Taylor Clayton) share a young daughter, E.W., born in March 2022. According to the opinion, E.W. is nearly blind, has a growth-hormone deficiency, and has several developmental delays. In 2023, the parents mediated an agreement to share joint legal and joint physical custody, and the district court adopted that agreement, setting up a schedule where E.W. rotated between her parents every two or three days. Things changed when Taylor became engaged to a military servicemember being transferred to a base near San Diego, California. In February 2024, Taylor asked the court for primary physical custody and permission to move to California with E.W. Bryce opposed that request and asked for primary physical custody himself. By the time of the hearing, Taylor had married. At a January 2025 evidentiary hearing, both parents testified. Even though Taylor had asked for primary custody, she said she would be open to continuing to share custody, suggesting a two-weeks-on, two-weeks-off arrangement. She testified that E.W. needed regular specialist visits and twice-weekly therapy, but said she was not worried about continuity of care as long as E.W. had insurance and providers in both states. Bryce disagreed that a long-distance shared arrangement was in E.W.'s best interest, emphasizing E.W.'s need for stability, the difficulty of long car trips, and the importance of consistent therapists. At one point, Bryce told the court "it would be up to what you decide" because he "do[es]n't set custody . . . for a living." In March 2025, the district court denied both parents' requests for primary physical custody and effectively denied Taylor's request to relocate. The court found that Taylor had a good-faith reason for the move but had not shown that relocation was in E.W.'s best interest or offered an actual advantage. The court found that all of the best-interest factors were either neutral or did not apply, and concluded that both parents were fully capable of caring for E.W. The court kept joint physical custody in place, but — to address Bryce's concern about frequent travel — ordered a one-month-on, one-month-off schedule instead of the two-week rotation Taylor had suggested. On child support, the court kept the baseline obligation at $0 because the parents' incomes were similar, but ordered Taylor to pay Bryce $100 per month for transportation costs tied to her decision to relocate. Bryce asked the court to reconsider its custody and parenting-time decisions (but did not separately challenge the $100 transportation award), and the court denied that request. He then appealed. The Court of Appeals rejected each of Bryce's arguments. It held that his due process rights were not violated, because Nevada's custody statutes put him on notice that joint physical custody was a possible outcome once custody was before the court, and he had a chance to be heard on the issue. It held that the court did not abuse its discretion in finding a substantial change in circumstances (relying on a prior Nevada Supreme Court case involving a relocating military spouse) or in finding that joint custody with a monthly schedule served E.W.'s best interest — noting that much of Bryce's argument amounted to asking the appellate court to reweigh the evidence, which it does not do. Finally, it held that the court properly handled the $100 transportation award as part of the overall child support determination and that Bryce had not built a record showing the amount was inadequate. The court affirmed.