Nevada family-law case summaries

This is a custody dispute between two parents, Nereida Cobian and Armando Emmanuel Ramirez, who had a child, L.R., born in Utah in October 2015. Early on, the parents submitted a letter to a Utah court in which Ramirez appeared to give up his parental rights, but the court did not treat it as a full waiver. Instead, the Utah court gave Cobian sole legal and physical custody and gave Ramirez standard parenting time, and it required Ramirez to pay child support. Cobian moved with the child, first to California and later to Las Vegas. Ramirez, who worked for and then as a civilian contractor connected to the Air Force, moved to Las Vegas as well. Over time, conflict grew. According to the district court's findings, Cobian repeatedly restricted Ramirez's time with L.R., moved to California in June 2021 without Ramirez's consent or a court order, and reported Ramirez to California child-welfare authorities for physical and sexual abuse. That investigation ended with the allegations found "unsubstantiated or inconclusive." California, which had briefly taken emergency jurisdiction, gave jurisdiction back to Nevada in July 2022. Ramirez asked the Nevada court to register the Utah order and to change custody. After an evidentiary hearing that was rescheduled four times, the district court awarded Ramirez primary physical custody, gave the parents joint legal custody, ordered L.R. returned to Las Vegas and enrolled in a Las Vegas school for the spring semester, ended Ramirez's child-support obligation, and held Cobian in contempt (with a $500 fine) for blocking Ramirez's parenting time over Thanksgiving 2023. Cobian appealed. On review, the Court of Appeals rejected each of her arguments. It concluded that Nevada was the child's "home state" and that the district court properly had jurisdiction to register the Utah order and decide custody. It found no abuse of discretion in the district court's decision to keep the case in Nevada rather than transfer it to California, because Ramirez still lived in Nevada and the Nevada court was familiar with the case. It upheld the custody change, noting that the trial judge made detailed findings that circumstances had substantially changed and that the child's best interests favored Ramirez. The appellate court explained that it does not re-weigh evidence or second-guess a trial court's credibility findings, including the trial court's determination that Cobian's abuse allegations were not credible. It upheld the relocation order, the contempt finding, and it declined to order the case reassigned to a different judge, finding that Cobian had not shown bias. The court did not decide certain issues. It declined to address the child-support challenge in detail because that challenge depended on reversing the custody award, which the court affirmed. It found the school-enrollment issue moot because the order concerned only the 2024 spring semester. And it concluded it lacked jurisdiction over the attorney-fees issue because the order under appeal only found that Ramirez was "entitled to" fees rather than actually awarding them.