Nevada family-law case summaries

Nick Bryant and Megan Sorget were never married but share one child, S.B., born in 2013. From 2015 to 2021 they shared custody equally under an agreed court order. In December 2020, Sorget asked the court for permission to move to Michigan with S.B. to live with her husband; the court said no. Bryant was then given primary physical custody, and Sorget received summer and holiday time plus the option of ten additional days per month in Las Vegas with advance notice. Sorget moved to Michigan anyway (without S.B.), divorced her husband in February 2024, and moved back to Nevada in March 2024. Once back in Nevada, the parents could not agree on a new schedule. Bryant asked the court to adjust the timeshare while keeping him as the primary custodian; Sorget asked to return to the equal, joint custody schedule the parties had used before she left. After a temporary week-on/week-off schedule and an evidentiary hearing - a trial-like proceeding where witnesses testify under oath - the district court sided with Sorget. It found that her return to Nevada was a "substantial change in circumstances" (the legal trigger required before a court can revisit custody) and that joint physical custody was in S.B.'s best interest, pointing to factors such as the level of conflict between the parents, their ability to cooperate, and the child's developmental and emotional needs. The court also recalculated child support: because Bryant earns about $7,498 per month and Sorget was not working, the standard formula would have set his obligation at $1,080 per month, but the court reduced it to $500 per month after considering Sorget's household income of roughly $10,000 per month (supplied by her ex-husband, with whom she had reconciled) and her responsibility for her other two children. On appeal, the Nevada Court of Appeals upheld everything. It explained that appellate courts do not second-guess a trial judge's weighing of the evidence or decisions about which witnesses to believe; they ask only whether the findings are supported by "substantial evidence" - evidence a reasonable person could accept. The court found the record supported the conclusion that Sorget's return to Nevada changed circumstances in ways affecting S.B.'s welfare (more frequent contact, more availability for daily routines) and that the best-interest findings were adequately supported. On child support, the court held that Sorget's credible testimony - that caring for S.B., her two other children (one with cerebral palsy and other special needs), and her fiancé's five children left her unable to work outside the home - gave the district court good cause not to attribute pretend income to her, and that the district court adequately explained why it lowered Bryant's payment below the guideline amount. Sorget's claim on appeal that she is no longer with her ex-husband, which apparently arose after the hearing, was not considered because it was never raised in the district court, though the court noted she may raise it there as a possible basis to modify support going forward.