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.

The Ruckles had been serving as court-appointed guardians of their three granddaughters since January 2022, when a district court found that the children had been living with their mother, Sara Q., in squalid conditions and were thriving in the Ruckles' care. Over the next two years, Sara petitioned the court to begin reunification therapy - therapy designed to repair the relationship between a parent and her children - and the court eventually ordered the Ruckles, Sara, and the children to participate with a therapist named Dr. Stephanie Holland. Disagreements arose over the wording of the therapist's consent paperwork, and the therapy was slow to begin. Dr. Holland sent the court two confidential reports under NSRG 5, a rule that allows a guardianship judge to receive certain communications about a guardian's conduct or a protected person's welfare. After receiving the second report, the court issued a July 13, 2024 order expressing "significant concern" about the Ruckles' compliance with their duties, ordered the children to undergo psychoeducational testing, expanded Sara's visitation, and set an NSRG 5 hearing for July 25 to address the issues raised in Dr. Holland's report. One day before that hearing, Sara filed a petition asking the court to remove the Ruckles and terminate the guardianship. The court did not issue the formal "citations" (legal notices) that Nevada statutes require when such a petition is filed, and there is no indication the petition was set for any hearing. At the July 25 hearing, which lasted only seven minutes, the district court announced - without taking evidence, hearing argument, or directing briefing - that it was removing the Ruckles as guardians and terminating the guardianship. When the Ruckles' lawyer tried to speak, the judge said, "I understand you've stood up, but I've made my orders. I am terminating the guardianship today." The court told counsel he could file a motion for reconsideration. A written order followed in October 2024. The Ruckles appealed, arguing that they had a constitutional right to procedural due process - basic fairness, including notice and a chance to be heard - before a court could strip them of guardianship, and that they did not get either. The Court of Appeals agreed. Building on the Nevada Supreme Court's 2023 decision in In re Guardianship of D.M.F., the Court of Appeals expressly held that a custodial relative who serves as a guardian has a constitutionally protected liberty interest in the care, custody, and management of the child, and is therefore entitled to notice and an opportunity to be heard before a court may, on its own initiative, remove the guardian and terminate the guardianship. The court found the notice given here was inadequate. The July 13 order flagged concerns but did not signal that removal or termination was being considered. Sara's last-minute petition came too late and was not accompanied by the statutorily required citations. And even if notice had been adequate, there was no meaningful opportunity to be heard because the district court issued its ruling at the start of a brief hearing, without briefing, evidence, or argument. Rather than simply reversing, the Court of Appeals vacated the order and sent the case back. Because Dr. Holland's confidential reports were not in the appellate record - and because Sara's petition described serious allegations including alleged emotional, psychological, and physical abuse and educational neglect - the court directed the district court on remand to permit briefing, hold an evidentiary hearing, and make the specific findings required by Nevada statutes and the NSRG before deciding whether removal or termination is warranted. In the meantime, the children will remain in Sara's physical and legal custody pending the district court's decision, although the trial court retains authority to enter temporary or emergency orders if circumstances require. The Court of Appeals also noted that the matter is moot as to the eldest child, A.L.R.-Q., because she has turned 18.

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.