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.

Alfredo and Cristiane have two children together but never married. When their relationship ended, the children lived with Cristiane while Alfredo lived in Australia working as a circus performer. In December 2018, Cristiane filed a complaint asking for child custody, future child support, and arrears (past-due child support) dating back to 2007. Alfredo also filed his own custody complaint, in which he proposed paying $600 per month in child support. The district court combined the two cases. Because Alfredo was in Australia and did not answer, the court entered a default order in May 2014 giving Cristiane custody but leaving child support unresolved. After Alfredo moved to Las Vegas in 2016, the court granted him parenting time and set his child support at $600 per month in a June 27, 2016, order. Cristiane also filed a separate motion to review arrears going back to January 2014, but the court vacated that hearing. Alfredo then moved to reduce his support to $300, and at an August 18, 2016, hearing the court reduced his support and ordered him to pay $30 per month toward arrears. The written order from that hearing was not filed until June 2017 and left out language the court had stated at the hearing about how Cristiane should pursue arrears. In April 2022, Cristiane asked the court to hold Alfredo in contempt for failing to pay arrears and to modify his support based on his income. In August 2022, she asked the court to amend the August 2016 order to make clear she was entitled to arrears. Alfredo opposed, arguing the statute of limitations (a legal deadline for bringing a claim) had run out. After an October 2022 evidentiary hearing, the court amended the 2016 order "nunc pro tunc" - a Latin phrase meaning "now for then," used to correct a record to reflect what was actually decided earlier - to add the language that Cristiane could seek arrears. The court found the parties had a verbal agreement that Alfredo would pay $600 per month, that he was current until December 2013, and that he owed $47,160 in arrears plus $24,360 in interest. It also awarded $14,890 as a lump sum from Alfredo's "America's Got Talent" earnings and said attorney fees and costs were warranted. On appeal, the Court of Appeals agreed with the district court that Cristiane was entitled to arrears for December 2013 through July 2016. The court explained that the parties had a verbal agreement, that Alfredo had admitted in his own custody complaint that he would pay $600 per month, and that filing deadlines did not bar the claim because Cristiane's 2013 complaint tolled (paused) the statute of limitations. The court declined to consider Alfredo's laches argument because he raised it for the first time on appeal, and did not address the attorney fees issue because the fee order was not part of this appeal. However, the court agreed with both sides that the district court got the math wrong. Both parties agreed that a second amended schedule of arrears correctly listed $27,600 in arrears and $9,128.41 in interest, not the higher $47,160 and $24,360 figures in the order. It was also unclear from the record whether the $14,890 lump sum had already been paid. For those reasons, the court sent the case back for the district court to recalculate the amounts.