Nevada family-law case summaries

Maria and Kevin Elder married in 2012 and have two children. When they divorced in 2020, both agreed that a prenuptial agreement — a contract signed before marriage — validly waived community property and alimony, and they stipulated to joint legal and physical custody of the children. That left one issue for the trial court: how much child support Kevin would pay. At a December 2021 hearing, the parties announced a settlement under which, instead of monthly child support payments, Kevin would fund a trust that would pay out money to Maria for the children's expenses. For purposes of that stipulation, they agreed Kevin's monthly gross income was $500,000. But the settlement fell apart when the parties could not agree on the trust's terms, and the district court declined to enforce it because it was premised on Kevin's child support being nonmodifiable and on the court giving up jurisdiction over future child support issues. The court entered a divorce decree in September 2022 and set an evidentiary hearing on child support for October 2023. Maria fired her lawyer and did not attend that hearing. Kevin presented evidence that his average monthly gross income was $125,000, and in October 2023 the court set his child support obligation at $8,000 per month under the child support guidelines. Maria did not appeal that decision. A year later, in October 2024, Maria asked the court to modify child support, arguing it should have used the $500,000 income figure from the failed settlement, which would have entitled her to roughly $32,000 per month. The court denied the motion, finding she had not alleged any changed circumstances, and she did not appeal. In January 2025, she filed two largely identical motions making the same argument. The district court denied them, essentially determining that Maria failed to demonstrate changed circumstances warranting review and that she failed to establish a factual or legal basis for relief. On appeal, the Court of Appeals affirmed. It explained that a court can only modify child support when circumstances have changed since the last order and the change serves the children's best interest. Maria's brief did not address the March 2025 order she was actually appealing; instead it attacked the earlier 2022 decree and 2023 support order. Because challenges to those earlier rulings had to be raised in a timely appeal from the October 2023 order, the court dismissed that portion of her appeal as untimely. The court also denied Maria's motion to submit new evidence, because appellate review is limited to the record and the motion concerned events occurring after the notice of appeal was filed, and it denied Kevin's request to sanction Maria.