Nevada family-law case summaries

Jashawn Prevost and Keilah Gronvold met in 2013 and had a child together in 2014. The family moved to Las Vegas in 2015 and lived there until the parents separated in 2020. After the separation, Gronvold moved to Mississippi while Prevost stayed in Las Vegas with the child. Prevost then filed a court case (representing himself) asking for custody, and Gronvold answered and filed her own counterclaim, also representing herself. The parties could not agree through mediation, so the case went to trial in April 2021. Both appeared virtually for a trial that lasted a single afternoon. Prevost called the child's teacher as a witness, who testified that the child had struggled in school until Gronvold left and that the child improved after Prevost became more involved. Prevost testified that he was the best parent and accused Gronvold's current partner of being a "pedophile and sex trafficker." By his own testimony, however, Prevost based those accusations only on what Gronvold had told him ("per her"). Gronvold testified that she wanted joint physical custody and to be able to see her child in Mississippi. She said she never told Prevost the things he used to support his accusations against her partner. She also described a relationship marked by repeated domestic violence, including beatings that required staples in her head, a black eye, being shot with a pellet gun, and threats to kill her. Neither party formally moved to admit their evidence during the trial. Before closing arguments, the judge asked whether the parties would agree to let her review each side's evidence. Prevost first objected, saying he could not open documents Gronvold sent through an app called OurFamilyWizard and that she should have sent them in another format, such as hard copy. The judge noted his objection but asked again whether he agreed to her reviewing the evidence, and Prevost answered, "Yes, ma'am." A few days later, the district court issued its decision. It found Gronvold credible, noted photographs showing her bruised and bloodied face, and found that Prevost had committed one or more acts of domestic violence proven by clear and convincing evidence resulting in severe injuries. Because of that finding, the court applied a legal presumption (an assumption the law makes unless proven otherwise) that Prevost should not receive joint or primary custody, and it found Prevost did not overcome that presumption. The court awarded primary physical custody to Gronvold and, applying the statutory factors, found the child's move to Mississippi to be in the child's best interest. On appeal, the Court of Appeals rejected all three of Prevost's arguments. It found that the record did not show the judge forced or "strongarmed" him into agreeing to the evidence review; she heard his objection, then asked again, and he agreed. The court also concluded that any problem with how Gronvold shared her documents was minor and did not change the outcome, especially because Gronvold's own credible testimony established the domestic violence. The court also held that the district court did not ignore Prevost's accusations against Gronvold's partner. Because those accusations rested entirely on what Prevost said Gronvold told him, and Gronvold denied ever making those statements, the trial judge was entitled to decide whom to believe. Finally, the court declined Prevost's request to reweigh witness credibility, explaining that trial courts, which see and hear the witnesses, are the ones who make those calls, and appellate courts do not second-guess them from a transcript. The court affirmed the custody decree.