Nevada family-law case summaries

Erin and Joseph Cornwall divorced in June 2022 and share four children. Under their divorce, they were given joint legal and joint physical custody of all four. In December 2024, Erin asked the court to change the custody arrangement, to interview the children about their preferences, to reset child support, and to award her attorney fees. She argued that Joseph's behavior had changed circumstances enough to justify revisiting custody. Erin raised several concerns. She alleged that in 2023 Joseph berated one of the twins, Sa.C., over chores, pushed him against an oven, held him there, and threatened him. She said the children began recording Joseph's outbursts after that incident and submitted a video showing part of it. She also alleged that Joseph reacted poorly to their daughter Sh.C. identifying as LGBTQ, installed surveillance equipment to monitor the children's communications with her, refused to use a parenting coordinator, did not properly treat a toe injury to F.C., failed to follow the summer schedule, and frustrated the children's access to mental health services. Joseph denied being violent, said Erin took his words out of context, and submitted texts and emails showing affection toward the children and efforts to arrange counseling. The district court held a hearing where lawyers argued, but it did not take live testimony. The court then denied Erin's motion. It reasoned that two of the children, Sa.C. and E.C., would turn 18 within about 90 days, so the court would soon lose authority over their custody. For the two younger children, Sh.C. and F.C., the court found Erin had not made a strong enough preliminary showing to justify a full hearing. The court noted that the video did not actually show Joseph throwing Sa.C. against the oven or threatening him, found the toe-injury complaint too thin, found the denigration allegations too vague, and concluded that Joseph being less open-minded about Sh.C.'s sexual orientation was not, by itself, a basis to reopen custody. The Court of Appeals agreed with the district court on most points. It held the court did not abuse its discretion in declining a hearing on the allegations about Joseph's reaction to Sh.C.'s sexual orientation, his refusal to use the parenting coordinator, the summer timeshare, the mental health provider dispute, and the security equipment, because those allegations either did not amount to a substantial change in circumstances or were too vague. But the appeals court disagreed about the domestic violence allegation. The rule is that, when deciding whether a parent has made enough of a preliminary showing to earn a hearing, the trial court must accept the moving parent's specific factual allegations as true. Erin had alleged a specific act of violence against Sa.C. that occurred after the divorce decree. The district court should have treated that allegation as true. Importantly, Erin had never claimed the video captured the violence itself; she said the children only started recording afterward. So the court could not properly rely on the video's failure to show the violence as a reason to reject the allegation. The appeals court also said the fact that Sa.C. was about to turn 18 did not make the domestic violence evidence irrelevant, because the younger children Sh.C. and F.C. still lived in the home. Because of this, the Court of Appeals reversed the part of the decision denying a hearing on the domestic violence allegations and sent the case back so the district court can hold an evidentiary hearing on that issue. On remand, the court may decide whether to interview the children and may consider all relevant facts in determining what is in the children's best interest.

This case involves a custody dispute over V., a child born in May 2019 to Terry Rosser and Joan Taylor, who briefly dated but never married. According to the opinion, Rosser initially told Taylor she would be the child's primary caregiver, at one point during the pregnancy tried to self-terminate his parental rights, and eventually stopped communicating with Taylor. He was not present at the birth and sent only three messages over the next year. In April 2020, Rosser filed a complaint seeking joint legal and physical custody; Taylor counterclaimed for primary physical custody, sole legal custody, and child support, including retroactive child support. The trial was continued seven times and finally took place in November 2023. In the intervening years, problems accumulated. Rosser missed a large share of his scheduled parenting time - Taylor estimated more than 100 missed exchanges, over half his parenting time, and Rosser himself testified he missed dozens of visits. He refused to cooperate meaningfully in discovery (the pretrial exchange of evidence), refused during his deposition to say how much money he earned, and sent blank HIPAA authorizations when Taylor requested his medical records. He also fell behind on the $84 monthly temporary child support and refused to pay Taylor directly because he "just didn't want to interact ... with the mother at all." At trial, Rosser - who had been diagnosed with cancer - stipulated (formally agreed) that Taylor would have primary physical custody, but he still sought joint legal custody and requested four days a week of three unsupervised hours of parenting time. He also testified that he "[chose] not to [work], let's put it that way," that his father gave him over "six figures" each year, and that the court could impute (attribute) $4,000 to $5,000 a month of income to him. The district court awarded Taylor primary physical custody, gave Rosser two days a week of four-and-a-half unsupervised hours each, plus every Father's Day and Christmas Day and every other Thanksgiving and Easter, and granted Taylor sole legal custody after finding the parties' communication and cooperation were dysfunctional. It imputed Rosser's income at $8,333 per month, set child support at $1,147 per month, ordered $56,507 in retroactive support, required Rosser to pay the remaining medical expenses of V.'s birth and half of her health insurance, and awarded Taylor $60,000 in attorney fees. The Nevada Court of Appeals affirmed on every issue. It held that substantial evidence - evidence a reasonable person would accept as adequate - supported the finding that the parents' dysfunction rebutted the presumption favoring joint legal custody, pointing to the district court's findings that Rosser was dishonest and not credible, had long absences from V.'s life, and "views disagreement on nearly all issues involving [V.], many of which are trivial, [as] a game." On parenting time, the court noted Rosser had never exercised more than three hours a day and had missed a significant amount of his pretrial time; it also observed that the nine hours per week awarded nearly matched the twelve hours he requested, "which is akin to invited error" - a doctrine barring a party from complaining on appeal about something he asked for. The court rejected Rosser's argument that his schedule was really "sole" rather than "primary" physical custody, explaining that his time is unsupervised, occurs twice weekly, and includes holidays - unlike the highly restrictive arrangements that define sole physical custody. On money issues, the court held the imputed income was supported by Rosser's own testimony, that retroactive support was permitted (Taylor sought it when V. was one year old, and the statute allows recovery of up to four years of support furnished before the action), and that the statute making "[t]he father ... also liable to pay the expenses of the mother's pregnancy and confinement" is clear and unambiguous. Finally, the attorney fee award was upheld because the district court reviewed the required reasonableness factors and awarded significantly less than the $100,434.81 Taylor requested. A request to reassign the case to a different judge was deemed moot because the case was not being remanded and the trial judge no longer serves on the district court bench.

Paul and Jennifer Martinez divorced in California in 2015 and share a child, L.M. Jennifer received primary physical custody, and the parents shared joint legal custody. Jennifer later moved with the child to Nevada with court permission, and the case eventually transferred to Nevada courts. After further disputes, the Nevada district court increased Paul's visitation time and ordered Jennifer to pay all the costs of transporting L.M. to and from visits with Paul, reasoning that because Jennifer was the parent who moved away from California, she should bear those costs. Jennifer challenged two parts of that ruling: the order making her pay 100% of travel costs, and the decision to expand Paul's visitation beyond what the parties had specifically asked the court to address. On the travel-cost issue, the Nevada Supreme Court agreed with Jennifer. Nevada has a detailed administrative regulation, NAC 425.150, that lists factors a court must consider before adjusting child support away from the standard formula. One of those factors is the cost of transporting the child for visitation. The Court held that a district court cannot simply impose all travel costs on one parent as a stand-alone order; instead, those costs must be evaluated as part of the overall child support analysis, looking at the child's needs and both parents' financial circumstances. The district court's reliance on the fact that Jennifer had moved years earlier, by itself, was not a proper basis for assigning her all the costs. On the visitation issue, the Court sided with the district court. Although Jennifer argued she did not have fair notice that the court might broadly change the visitation schedule, the Court found she had put visitation squarely before the court (by asking that Paul's visits be supervised), testified at length on the topic, and had the chance to present evidence. The Court also found enough evidence in the record - including doctor notes and Paul's own testimony - to support letting Paul have a standard out-of-state unsupervised visitation schedule. The Court reversed the travel-cost portion of the order and sent the case back to the district court with instructions to apply the NAC 425.150 framework. It affirmed everything else and declined to sanction Jennifer for bringing the appeal.

This case involves a former married couple and their child. Alaa, a Syrian citizen, and Susan Swensen, a U.S. citizen, married in 2013 in the United Arab Emirates (UAE) and had a child there in 2014. In 2017 Susan and the child moved to the United States, settling in Nevada in July 2019. Alaa stayed in the UAE. According to the opinion, the parties kept in touch amicably through Facebook, email, and video calls. In May 2020, Susan started divorce and custody proceedings in Nevada, asking for joint legal custody, primary physical custody, and a change to the child's last name. Alaa was served with the papers but chose not to participate. He instead told Susan that he was not subject to U.S. law and that UAE law should apply. Because he did not respond, Susan obtained a clerk's default, and in March 2021 the court entered a default divorce decree granting joint legal custody, giving Susan primary physical custody, and approving the name change. No appeal was filed from that decree. More than two and a half years later, in October 2023, Alaa filed a motion asking the court to undo the divorce decree, return the child to the UAE for a custody decision, and restore the child's birth name. He said he had tried to begin divorce proceedings in the UAE in April 2020 but could not because he lacked the child's birth certificate and related documents. He said a UAE court issued its own default divorce decree in August 2020 but declined to decide custody, and that this UAE decree was never shown to the Nevada court before it entered its decree. He argued Susan had unlawfully removed the child from the UAE. Susan opposed the motion and asked for an abduction prevention order. She argued the motion was too late under the rule governing motions to set aside judgments, that Nevada was the child's home state, that their communications contradicted the abduction claim, and that Alaa had not shown reversing the name change was in the child's best interest. The district court denied Alaa's motion. It found no factual or legal basis to set aside the decree, noting the parties had communicated extensively after Susan left the UAE and that the child had lived in Nevada for more than six months before Susan filed for divorce. The court found Nevada was the child's "home state" and the United States the child's "home country," giving it authority (jurisdiction) over the case. It also noted Alaa could have participated in the Nevada proceedings but declined to, and had not requested parenting time. On appeal, the Court of Appeals affirmed. It concluded the district court properly had authority over the custody dispute because Nevada was the child's home state and no competing custody proceeding existed in the UAE when Susan filed in Nevada. The court also rejected the abduction argument, pointing to the parties' friendly communications in the record. Finally, the court declined to consider several of Alaa's other arguments because he had either not raised them properly in the lower court or had raised them too late.

This case is a dispute between two parents, Austin Patterson and Kalena Wainwright, over the custody of and financial support for their minor child. Wainwright originally asked the court for sole legal custody and primary physical custody, along with child support that would include child care costs (which she said ran about $2,000 per month). Patterson answered and asked for joint legal and physical custody. Both parents submitted financial disclosure forms: Wainwright reported earning about $5,934 per month, and Patterson reported earning $1,950 per month. At first, the court entered a temporary order giving both parents joint legal and physical custody and directing Wainwright to pay Patterson $328 per month in temporary support. Wainwright later asked the court to change that arrangement, arguing that she was the child's primary guardian and was paying the child's ongoing care and education costs. She also raised concerns about Patterson's conduct. Patterson opposed her request and disputed her allegations. After an evidentiary hearing where both parents testified, the district court entered a written order. It kept joint legal custody but gave Wainwright primary physical custody. The court walked through the "best interests of the child" factors that Nevada law requires it to consider and found several of them favored Wainwright. Among its findings: Patterson did not give credible testimony about the child's medical issues, failed to make sure the child received proper medical care and physical therapy (including for the child's toe walking), did not communicate with Wainwright about the child's medical needs, kept two dogs in his home even though the child has allergy-induced asthma and is allergic to dogs, and did not work full-time. Because of these findings, the court also decided Wainwright should have the final say on medical decisions if the parents disagreed. On money, the parties agreed after the hearing that the child would attend a child care program costing $1,375 per month. The court ordered that cost split evenly, so each parent would pay $687.50 per month. The court also split the child's medical costs and gave Wainwright $52.83 per month for Patterson's share of the medical insurance premium. The court calculated Patterson's basic support at $312 per month based on his stated income, declined to increase (impute) his income even though he mentioned "side gigs," and declined to reduce his obligation for his other children. In total, Patterson's monthly support obligation came to $1,052.33. Patterson appealed. He argued the court got the custody decision wrong, misread his testimony, focused too much on his low income, wrongly refused to lower his support for his other children, and should not have made him pay $687.50 for child care, which he said was really a preschool and could have been cheaper. The appeals court ruled partly for each side. On the custody decision and the basic $312 support calculation, the court explained that a party who appeals must provide transcripts of the hearings where the evidence was presented. Patterson requested transcripts but never filed them with the court. Without the transcripts, the appeals court said it had to assume the missing records supported the district judge's findings, so it upheld those parts of the decision. But on the child care costs, the appeals court found a problem it could see on the face of the order itself. Nevada regulations require a court to consider whether child care costs are reasonable and whether splitting them is fair (equitable). The district court's order did not make findings on either point, and it did not explain how an even split was fair given that Patterson earns only $1,950 per month while his total support obligation climbed to $1,052.33. The court also did not make a finding on whether the parents had actually agreed to split the child care costs equally (as opposed to merely agreeing on the program). Because the order lacked these findings, the appeals court declined to assume the missing transcripts filled the gap and reversed the child care cost portion, sending it back to the district court to reconsider.

This case is a custody dispute between two parents. David D. Hines, Jr., filed a second amended complaint asking the court to declare him the child's father (DNA testing showed he was), to put his name on the child's birth certificate, and to give him sole legal and physical custody. He alleged that Boyd had a history of domestic violence and that child protective services had become involved with the child. Boyd did not dispute that Hines was the child's biological father, but she asked for sole legal and physical custody herself and pointed out that Hines lived outside Nevada, in Houston, Texas. The parents agreed on some parenting issues but not all, so the district court held an evidentiary hearing - a court proceeding at which witnesses testify and evidence is presented. Hines testified about learning he was the child's father through DNA testing, about child protective services removing the child from Boyd's custody, and about Boyd refusing to cooperate with court-ordered parenting time in Houston. Boyd testified about her criminal history, including a prior charge for child abuse and neglect and a felony grand larceny conviction, and about a violent incident with a former boyfriend that led child protective services to remove the child from her care for a time. She explained that she no longer had contact with the former boyfriend and that the child had been returned to her. The district court gave the parents joint legal custody but awarded Hines primary physical custody, meaning the child would live primarily with Hines in Texas. The court walked through the "best interest of the child" factors that Nevada law requires courts to consider. It acknowledged that Boyd was the victim of domestic violence, but it also found there had been ongoing domestic violence between Boyd and her former boyfriend that occurred in front of the child - including an incident in which a firearm was discharged - that the child had spent six months in foster care because of the risk of danger, and that Boyd had demonstrated a lack of capacity to protect the child. The court also found Boyd had interfered with Hines' parenting time. On appeal, Boyd argued the district court's findings were not supported by the evidence, that the court failed to properly weigh the required factors, that it did not understand she was the victim in the domestic-violence incident, that it did not let her participate in decision-making about the child, and that it did not consider the disruption of moving the child out of Nevada. The Court of Appeals rejected these arguments. Appellate courts review custody decisions only for an "abuse of discretion" - a deferential standard - and will not re-weigh evidence or second-guess a trial judge's assessments of witness credibility. Because the district court's factual findings were supported by substantial evidence in the record, the Court of Appeals found no abuse of discretion. Boyd also argued that the district court judge was biased against her. The Court of Appeals rejected that argument too, explaining that Boyd had not shown the court's decisions were based on knowledge acquired outside the proceedings or that they reflected "a deep-seated favoritism or antagonism that would make fair judgment impossible." The custody decree was affirmed.

Christopher Fisher and Elia Cobian were never married but were in an on-again-off-again relationship, and their daughter, L.F., was born in May 2019. The relationship ended after a physical altercation in April 2020 in which each parent accused the other of being the aggressor; no arrests or charges resulted, but Elia obtained a temporary protection order from the Elko Justice Court that gave her sole legal and physical custody of L.F. Both parents then went to district court seeking custody. A court-ordered custody evaluator recommended that the parents share joint legal and joint physical custody, and the case proceeded to a two-day evidentiary hearing in February 2022. At that hearing, the court heard testimony about Christopher's 2018 DUI conviction, his ongoing alcohol use, his partner's alcohol use, his refusal to give Elia his address, his estranged relationships with children from a previous relationship, health issues L.F. experienced, and his failures to tell Elia when he traveled out of town with the child. Christopher also acknowledged an incident involving a daughter from a previous relationship in which the Utah Division of Child and Family Services substantiated an abuse and neglect charge against him. Nevada law requires courts deciding custody to weigh a list of "best interest of the child" factors. The district court found that eight of the twelve factors favored Elia and that the rest were neutral or inapplicable, so it awarded her primary physical custody, with Christopher receiving parenting time from Sunday morning through Tuesday afternoon every other week. After hiring a new lawyer, Christopher asked for a new trial, arguing his trial counsel failed to present any evidence on his behalf; the district court denied that motion, and he appealed. The Nevada Court of Appeals affirmed. Christopher argued that the district court had to first work through the statutes expressing a preference for joint physical custody before analyzing the best-interest factors. The appellate court explained that the sole consideration in a custody decision is the best interest of the child, and that even though the district court did not explicitly cite those preference statutes, it recognized the preference for joint custody but specifically found that "joint custody was not appropriate" under the totality of the circumstances. The court of appeals also declined to reweigh the evidence or the district court's credibility determinations, concluding that substantial evidence - evidence a reasonable person could accept as adequate - supported the ruling. As for Christopher's complaints about the court considering events before L.F.'s birth and allegations he said were not properly noticed, the appellate court held those objections were waived because he did not raise them in the trial court. It added that a district court may consider a parent's past conduct when determining a child's best interest, and that any error was harmless because the district court made numerous findings about the current custodial circumstances. Finally, the court noted one clerical mistake: page 12 of the district court's order erroneously refers to awarding Christopher primary physical custody, and it sent the case back solely to fix that error.

This is a divorced-parents custody fight over an eleven-year-old boy, H.R. The mother (Maggie) and father (Jason) had shared the child equally for years under a 2017 stipulated order. In 2020, Maggie asked the court to give her primary custody, saying H.R. had become aggressive and disrespectful toward her, which she blamed in part on Jason's influence. Jason countered with his own request for primary custody. A court-appointed therapist who evaluated the family thought Jason might be engaging in "parental alienation" - turning the child against the other parent - and recommended keeping the week-on/week-off schedule. The court initially adopted that recommendation. Things then got worse. On two occasions, H.R. was taken into police custody for hitting Maggie - once after Maggie's mother called police, once after Jason called. After those incidents, the district court entered an emergency order giving Jason "sole physical custody" temporarily, restricting Maggie to six hours of parenting time per week and reunification therapy with a specific therapist, Dr. Sunshine Collins. Later, the court tightened the restrictions further: Maggie could have no contact with H.R. except through Dr. Collins's therapy sessions. Because Dr. Collins was outside Maggie's insurance and required individual sessions before any joint sessions with H.R., and because Maggie struggled to afford it, the practical effect was that Maggie had no contact with her son for six months. After a March 2022 evidentiary hearing, the district court labeled its final order "primary physical custody" to Jason but limited Maggie's parenting time to cards, texts, and phone calls - no in-person time at all - with any expansion left to Dr. Collins to decide. The court also ordered Maggie to pay Jason over $11,000 in attorney fees because he was the "prevailing party." The Court of Appeals affirmed the decision to change custody (because there was enough evidence of a substantial change in circumstances - the deteriorating relationship and H.R.'s wishes), but reversed the parenting-time portion and vacated the fees. The court used this case to define "sole physical custody" for Nevada law for the first time: it is an arrangement where the child lives with only one parent and the other parent has "no significant in-person parenting time." The court explained that calling something "primary physical custody" does not change what it actually is - if a parent has only cards and phone calls, that is sole physical custody. The court held that before a judge enters a sole physical custody order, the judge must either find the noncustodial parent unfit, or make specific written findings explaining why primary physical custody is not in the child's best interest. The judge must then choose the least restrictive parenting arrangement possible, and if a less restrictive option (like supervised visits) is available but rejected, the judge must explain why on the record. The district court here did none of those things. The court also held that the trial judge improperly delegated decision-making power to Dr. Collins by letting the therapist decide when Maggie's parenting time could be expanded. Under Nevada law, only the court itself can decide substantive custody questions. The opinion further faulted the final order's specificity: it incorporated only an oral mid-hearing statement called "the March 11, 2022, Order," which was never reduced to writing in detail, making the order unenforceable. The attorney-fee award was vacated because being the "prevailing party" alone is not enough to justify fees in a custody case - the court must make additional findings under the relevant statute, and the trial judge did not. Finally, the Court of Appeals took the unusual step of directing that the case be reassigned to a different judge on remand. The court pointed to multiple statements by the trial judge that, in the appellate court's view, raised reasonable doubts about her impartiality - including comments that children listen better to men because of "fisticuffs," that being a stepmother is harder than being a biological mother, and statements indicating the judge had made up her mind before Maggie put on her case.

Mark and Margaret Summit were divorced, and their divorce decree gave Margaret primary physical custody of their minor children, with Mark receiving parenting time and a child support obligation. Over several years, the couple repeatedly returned to court, largely because Mark asked the court to change the custody arrangement to either primary custody for himself or joint physical custody, and to adjust his child support accordingly. Margaret opposed these requests. Earlier disputes produced multiple appeals; in one, the Court of Appeals sent the case back to the trial court because the trial court had denied Mark's request to change custody without first holding an evidentiary hearing (a hearing where witnesses testify and evidence is formally admitted). After that hearing on remand, the trial court denied Mark's request to change custody. The court found that Mark had not shown a "substantial change in circumstances affecting the welfare of the child," and had not shown that changing custody was in the children's best interest. The court delayed deciding the child support issues because Mark had not filed an updated financial disclosure form, and it ordered him to file one with supporting documents such as tax returns, bank statements, proof of expenses, and a Paycheck Protection Program (PPP) loan application his business had submitted during the COVID-19 pandemic. Mark repeatedly submitted only some of the required documents. Eventually, the trial court ruled on child support, increasing Mark's monthly obligation from $200 to $1,887.98 and finding he owed $33,966 in back child support (arrears). Because the court found Mark's 2020 tax return "wholly incomplete and inadequate" due to missing documents, it based its income calculation largely on his financial disclosure form and on his PPP loan application, in which he had reported that his business received $133,000 in net revenue over a 12-month period. On appeal, Mark argued the trial court ignored or mishandled his evidence on custody. The Court of Appeals explained that many of the materials Mark attached to his written motions were never formally admitted into evidence at the hearing, so the trial court could not treat them as proof. Because Mark did not specifically challenge the trial court's decisions about what evidence to admit or exclude, the appellate court treated that challenge as waived. The court also noted that it does not re-weigh evidence or judge witness credibility on appeal. Mark also claimed the trial judge was biased, but the court found he had not shown the kind of deep-seated bias required to disqualify a judge. On child support, Mark argued the trial court wrongly relied on his PPP loan application and that the figure was outdated because his business had shut down during the pandemic. The Court of Appeals found that Mark had not actually submitted all the documents he was ordered to provide, so the trial court's finding on that point was supported by the evidence. The appellate court acknowledged that the trial court had overlooked some documents Mark filed earlier (such as his 2018 and 2019 tax returns and 16 months of business bank statements), but concluded Mark failed to show that these overlooked documents would have changed the result. Mark also had not provided the appellate court with the hearing transcript, and Nevada appellate courts presume that missing parts of the record support the trial court's decision. Finally, on the attorney fees and costs issue, the Court of Appeals concluded it lacked jurisdiction (legal authority to decide the issue) because the trial court's order on fees was not final — the court had granted part of Margaret's request but planned further proceedings on the rest. The appellate court therefore dismissed that part of the appeal as premature and affirmed the rest.

Maggie Cox and Jason Roe divorced and shared joint custody of their son, H.R. About seven years later, when H.R. was eleven, Maggie asked the court to give her primary physical custody, saying the boy's behavior toward her had become disrespectful and aggressive, which she blamed partly on Jason. Jason opposed and asked for primary custody himself. The court ordered therapy and a "brief focused assessment" by a therapist, Maureen Zelensky. Zelensky's report suggested Jason was likely engaging in "parental alienation" (a dynamic in which a child becomes excessively hostile toward one parent) and that Maggie likely had anxiety and possibly post-traumatic stress disorder. She recommended keeping the shared week-on-week-off schedule and issuing behavior orders for both parents, which the court adopted. The situation then worsened. On two occasions, police took H.R. into custody for battery against Maggie during her parenting time; H.R. was found to be the primary aggressor both times. The opinion notes that Maggie never called the police—her mother called once and Jason called once—and that once police were called, Nevada law generally requires an arrest and a 12-hour detention. Based on those incidents, Jason filed an emergency motion for sole custody. In March 2021, the court granted it, making findings including that "something wrong with the parent who cannot manage an 11-year-old," that Maggie had called the police (which the record contradicts), and that her behavior was "histrionic." The court sharply restricted Maggie's contact with H.R., limited her to reunification therapy with Dr. Sunshine Collins and six hours of parenting time weekly, and appointed a parenting coordinator and a guardian ad litem, with costs split between the parents. Over the following months, contact between Maggie and H.R. was further restricted. Dr. Collins was outside Maggie's insurance network and Maggie fell behind on payments; Dr. Collins required Maggie to complete individual sessions before joint sessions with H.R. In September 2021, the court granted Jason's objection and ordered Maggie to have no contact with H.R. outside of therapy with Dr. Collins—effectively barring all contact between mother and son. This prevented Maggie from contacting H.R. on his birthday and from sending gifts or cards over the holidays. Learning this midway through a later hearing, the court orally modified the order to let Maggie send cards, texts, or calls. At the end of the March 2022 hearing, the court kept joint legal custody but gave Jason "primary physical custody," finding a substantial change in circumstances (the deteriorating relationship between Maggie and H.R.) and that H.R.'s best interests favored living with Jason. In practice, Maggie received no in-person parenting time—only cards, texts, and calls—and any expansion of her time was left to Dr. Collins's discretion. The court also ordered Maggie to pay $11,365 in attorney fees and costs to Jason as the prevailing party. The Court of Appeals reached a split result. It agreed there was substantial evidence supporting the decision that circumstances had substantially changed and that primary physical custody should go to Jason, so it affirmed that part. But it held the district court went too far in limiting Maggie's parenting time—so far that it effectively awarded Jason sole physical custody without adequate justification, cutting off a mother with no criminal history, no substance-abuse history, and no history of domestic violence from any in-person time with her son for over a year. The court also held the district court improperly handed off its own decision-making authority to Dr. Collins by letting her decide when Maggie could see H.R. in person, and that the final parenting-time order was too vague to enforce because it merely referenced an unwritten oral ruling. The Court of Appeals further concluded the case should be reassigned to a different judge on remand, pointing to statements and findings in the record that could cause a reasonable person to question the judge's impartiality. Finally, it vacated the attorney-fee award because the required findings were missing and because part of the underlying order was being reversed.

Jennifer and Paul Martinez divorced in California, where Jennifer received primary physical custody of their child, L.M., and permission to move with the child to Nevada. Once the Nevada courts took over the custody case, Paul asked for primary physical custody. Jennifer opposed that request and asked the court to require that Paul's time with the child be supervised until he underwent a neuropsychological evaluation confirming he could care for L.M. without supervision. Both parents also asked the court to change the parenting-time schedule. After a hearing where evidence was presented, the district court kept primary custody with Jennifer but gave Paul more parenting time than before, refused to require supervision, and declared Paul the "prevailing party" - the side that won - for purposes of attorney fees and costs. Jennifer appealed. The Nevada Court of Appeals rejected each of Jennifer's arguments. First, she argued the district court went beyond its power and violated her due-process rights by giving Paul more parenting time than he asked for. The court disagreed, explaining that the parenting-time schedule was squarely before the district court because both parties had asked to change it. Even where the parents' proposed schedules overlapped, the district court was not locked into those points of agreement - Nevada law requires courts deciding custody matters to evaluate what is in the child's best interest. Second, Jennifer argued the hearing should not have gone forward because Paul allegedly failed to turn over medical records as previously ordered. The court found she cited no relevant discovery or evidence rules and presented no cogent argument, and noted that district courts may revise their earlier, non-final orders at any time before final judgment. Third, on the merits of the new schedule, the appeals court reviews such decisions only for "abuse of discretion" - meaning it will not second-guess the trial judge unless the decision was outside the bounds of reason. The district court addressed all the statutory best-interest factors, and the appellate court does not reweigh conflicting evidence or revisit credibility calls. Even if the trial court misread some individual pieces of evidence, the appellate court could not say the overall result would reasonably have been different. Fourth, Jennifer argued the district court failed to make required findings before ordering her to pay all costs of transporting L.M. to and from California for Paul's parenting time. The court agreed with Paul that the travel-cost order was not an adjustment of child support - the court set child support at the standard base amount and separately ordered Jennifer to pay travel costs because she was the relocating parent - so the regulation requiring those findings did not apply. Finally, because the district court had only declared Paul a prevailing party and had not yet actually awarded any fees or costs, Jennifer's challenge to any award was premature; such an award can be appealed once it is actually entered. The Court of Appeals affirmed the district court's judgment.

This case concerns two parents fighting over custody of their two young children after a divorce. Jasper and Carlos married in 2013 and divorced in 2017. They had two children, born in 2014 and 2016. Shortly after the divorce, both parents agreed in a court filing that Jasper would have sole legal and physical custody. In 2019, they again agreed that Jasper and Jasper's new husband could move with the children to Hampton, Virginia. In January 2021, Carlos asked the court to change the custody arrangement. His concerns focused on the children's gender fluidity and on Jasper's decision to support the use of certain strong psychiatric medications prescribed to one child. The court issued a temporary order in May 2021 giving Carlos joint legal custody, meaning both parents would share decision-making. Jasper's own attorney wrote that order, and Jasper did not object to it or ask the court to pause it. Two later disputes became important. First, the parents disagreed about whether to vaccinate the children against COVID-19; Jasper wanted to, Carlos did not. Second, an earlier 2019 order gave Carlos time with the children for Christmas 2021. Jasper asked the court either for permission to vaccinate the children or to postpone the Christmas visit. The court denied that request in early January 2022. By then, Jasper had already kept the children from Carlos over Christmas, in violation of the 2019 order. Then, right after the court's denial, Jasper had the children vaccinated and boosted anyway, against Carlos's wishes and against the court's temporary order. In May 2022, after a full-day hearing with testimony from both parents, Carlos's wife, and a clinical psychologist the parents had jointly hired, the court issued a 39-page order. It gave Carlos primary physical custody while keeping joint legal custody shared. The court did not agree that the children's gender fluidity was a "substantial change of circumstance." Instead, it found that Jasper's pattern of violating court orders and withholding Christmas visitation was the change of circumstances that justified revisiting custody. The court then went through each factor the law requires for deciding a child's best interest and concluded that primary physical custody with Carlos served the children's best interest. Because this required the children to move from Virginia back to Nevada, the court also applied the relocation rules and found relocation was warranted. On appeal, Jasper raised four arguments. The appeals court rejected all of them. It held that Jasper had waived the challenge to the temporary order by not objecting to it below, and that Jasper had treated that order as valid anyway. It held that the orders Jasper violated were not void or unenforceable. It held that the district court did not change custody merely to punish Jasper, because the court properly analyzed the required best-interest factors and found several that favored Carlos for reasons unrelated to the order violations. And it held that Jasper had not shown the court was biased against Jasper's transgender status, noting that the statements Jasper pointed to were made by Carlos, not the judge, and that a judge's rulings alone almost never prove bias. The court affirmed the custody modification. The court also declined Carlos's request to sanction Jasper, finding the appeal as a whole was not frivolous.

Burke Hall and Vanessa Marie Loftis were married and had three minor children. Their youngest child died in a tragic accident, drowning in a swimming pool while Loftis failed to provide adequate supervision. Loftis was convicted of a felony count of child abuse, neglect, or endangerment in connection with that accident and placed on probation. (After she was discharged from probation, her conviction was reportedly reduced to a gross misdemeanor, but the amended judgment of conviction was not in the record before the appeals court.) Loftis then started this court case, asking for "separate maintenance" (financial support while remaining married) and for joint legal and physical custody of the two remaining children. Hall responded by asking for a divorce and for sole legal and physical custody of the children. The district court granted the divorce early on but waited to decide the heavily contested custody dispute. Both sides made serious accusations against each other, including claims of abuse, domestic violence, mental health problems, and withholding the children. After a multi-day evidentiary hearing, the district court awarded Loftis sole legal custody and primary physical custody, with discretion to let Hall have supervised parenting time. The court explained that this arrangement was in the children's best interest. It found that although Loftis committed an act of child abuse or neglect connected to the child's death, she afterward took every step possible to redeem herself and become a proper parent. By contrast, it found that Hall bore extreme animosity toward Loftis that harmed the children, refused to cooperate, interfered with the children's relationship with their half-siblings, showed potential mental health issues while refusing to obtain a psychological examination, and committed an act of abduction without just cause. On appeal, Hall first argued the district court had no power (jurisdiction) to grant a divorce because Loftis had only asked for separate maintenance, not divorce. The appeals court rejected this because Hall himself filed a counterclaim for divorce, and Nevada law allows a court to grant a divorce to either party when grounds exist. Hall also argued that a separate divorce case he had previously filed blocked the court's jurisdiction, but he had agreed to dismiss that separate case, and the court found no legal authority creating such a barrier. Hall next challenged the custody decision on three main points. He said the court ignored Loftis's role in the child's death; the appeals court disagreed, noting the court did find Loftis committed abuse or neglect but treated the factor as "neutral" because she had worked to redeem herself, a conclusion supported by evidence including her testimony and the guardian ad litem's testimony. Hall argued the court should have applied a legal presumption against giving custody to a person who commits domestic violence; the appeals court held the drowning did not amount to "domestic violence" under the statute's definition, so the presumption never applied. Hall also argued the court had no jurisdiction to make findings about child abduction because that is a criminal matter; the appeals court held that the family court does have jurisdiction over custody proceedings and that the best-interest statute specifically requires it to consider whether a parent committed an act of abduction. Finally, Hall raised complaints about the district court striking materials he had submitted. The appeals court agreed the district court was correct that exhibits are not evidence until admitted, but said striking them on that basis was an abuse of discretion because the rules contemplate filing exhibits not yet admitted. Even so, the court held any error was harmless because there was a full evidentiary hearing where both sides could offer their materials. Because appellate courts do not reweigh evidence or credibility, and substantial evidence supported the district court's conclusions, the appeals court affirmed. It noted that Hall remains free to seek parenting time and is not barred from revisiting the parenting-time arrangement.

Mehmet and Kathleen Kar divorced in Nevada. Their decree gave them joint legal custody, with Kathleen having primary physical custody and Mehmet getting visitation. Mehmet later moved to Turkey, and Kathleen, an Air Force servicemember stationed at Creech Air Force Base, obtained an order giving her sole legal and physical custody. The Air Force then reassigned Kathleen to England, and she took the child with her. Two months after Kathleen and the child arrived in England, Mehmet filed a motion in Nevada to modify custody and child support. Kathleen asked the Nevada court to dismiss the case, arguing that Nevada no longer had jurisdiction because nobody involved still lived there. The district judge agreed, saying that the "second" the mother and child moved to England, the court "lost jurisdiction." The judge dismissed the case. The Nevada Supreme Court reversed. It explained that the UCCJEA, the law that governs which state (or country) can decide custody disputes, has multiple layers. Yes, Nevada lost what is called "exclusive, continuing jurisdiction" once everyone moved away. But losing exclusive jurisdiction does not mean losing all jurisdiction. The Nevada court still had to ask whether it could exercise jurisdiction under a separate set of rules - the rules that govern when a state can make an "initial" custody determination - because the UCCJEA allows a court that previously decided a custody case to modify its order if those initial-jurisdiction rules are satisfied. Under those rules, Nevada could potentially still hear the case if (a) no other place qualified as the child's "home state" (a place where the child lived for at least six consecutive months), (b) the child and at least one parent still had a "significant connection" with Nevada beyond mere presence, and (c) substantial evidence about the child's well-being remained available in Nevada. At the time Mehmet filed his motion, the child had only been in England for two months, so England was not yet the child's home state. The court below never analyzed whether Nevada or England had a "significant connection" with the child or where the substantial evidence about the child was located. Those are factual questions, and the Supreme Court ruled that the district court must answer them. The Supreme Court also addressed Kathleen's argument that Nevada was an "inconvenient forum" and that England was a better place to litigate. Even if that were true, the UCCJEA does not allow the court to simply dismiss the case. It must stay (pause) the case and direct the parties to file in the more appropriate forum, so that the family is not left "in limbo" with no court anywhere to decide their dispute. The Supreme Court sent the case back so the district court can perform the full jurisdictional analysis the UCCJEA requires. The opinion did not decide whether Nevada actually has jurisdiction; it decided only that the district court must do the analysis instead of stopping at "everyone left."