Nevada family-law case summaries

Hope Backman and Daniel Gelbman share a child, D.G., born in 2013. They originally agreed to joint legal and physical custody. In 2018, after a hearing that showed substantial conflict between the parents, the district court kept joint legal custody but changed the physical-custody schedule. In 2023, Backman (then representing herself) asked to modify custody so she could move with D.G. to San Antonio, Texas, citing financial hardship, reduced income after the COVID-19 pandemic, and family support and job opportunities there. Gelbman opposed the move and filed his own request asking for primary physical custody, arguing circumstances had changed since 2018. Gelbman also asked the court to declare Backman a "vexatious litigant" (a person the court restricts from filing new matters freely), and Backman, through her lawyer, agreed to that designation in exchange for cancelling a scheduled hearing. That agreement required her future filings to go through a screening process before being accepted. The court appointed a custody evaluator, Dr. Herbert F. Coard III, who wrote reports about the parents' mental health and the child's situation. During the evaluation, the court temporarily gave Gelbman primary physical custody and limited Backman's contact with D.G., and by the time of the main hearing, Backman had gone many months without contact with the child. After a multi-day hearing, the court in March 2024 denied Backman's request to relocate and gave Gelbman primary physical custody. It kept "joint legal custody" on paper but gave Gelbman the final say over D.G.'s education and medical and mental-health care, while Backman kept information rights, emergency-care decision-making during her time with D.G., and joint authority over religion and extracurricular activities. Backman received alternating-weekend, holiday, and extended-summer time. The court declined to appoint a "parenting coordinator" (a neutral person who helps parents resolve disputes), reasoning that Backman could not afford to share the cost. The conflict continued. In early 2025, Backman filed an emergency motion claiming Gelbman's fiancée had physically injured D.G. The court screened the motion under the vexatious-litigant procedure, found it had arguable merit, and held a hearing. It then denied the motion, finding the injury was an accidental result of roughhousing rather than abuse. Gelbman asked for his attorney fees, and the court found Backman lacked a reasonable basis to keep pursuing the motion once the evidence was in. The court found more than $9,900 in fees reasonable but reduced the award to $2,000, payable at $100 per month, because of the parties' financial circumstances. Backman appealed both orders. The Court of Appeals rejected all of her arguments and affirmed. On the custody change, the court agreed the district court should have more clearly stated a separate finding that circumstances had "substantially changed" since 2018, but concluded the detailed factual findings already showed such a change, so any error was harmless. The court found the district court was not required to appoint a parenting coordinator, that giving Gelbman final say in certain areas was still a valid form of joint legal custody rather than a hidden grant of sole custody, and that the alleged bias of the evaluator went to how much weight his testimony deserved—not to whether it had to be thrown out. The court also concluded the vexatious-litigant designation was mentioned only in passing and did not drive the custody outcome, and that the attorney fees were properly awarded and reasonably calculated.

This case involves a dispute over the adoption of a child, G.P., among the child's relatives. Before G.P. was born, the birth mother asked the child's step-great-grandmother and great-grandfather, Katherine and Michael, to take temporary guardianship. They agreed and obtained temporary guardianship from a Washoe County court. The child's grandparents, Angela and Randall, then filed their own competing petition for guardianship in the same court. While the guardianship dispute was pending, the birth parents signed written consents to terminate their parental rights and to allow Katherine and Michael to adopt G.P. Katherine and Michael then filed an adoption petition in Clark County, where they live. The Clark County court, unaware that a guardianship case was pending in Washoe County, granted the adoption. When the grandparents Angela and Randall learned of the adoption, they asked the Clark County court to set it aside under a procedural rule (NRCP 60(b)) that lets courts undo judgments in cases of fraud, misrepresentation, or misconduct. They argued the great-grandparents had hidden the existence of the Washoe County guardianship case. The Clark County judge agreed and set aside the adoption. The Nevada Supreme Court reversed. The central question was whether the grandparents had "standing" — that is, the legal right — to ask the court to undo the adoption at all, given that they were not parties to the adoption case. The Supreme Court explained that only parties to a case, people in close legal privity with parties, or nonparties whose own legal rights are directly affected by the judgment can file an NRCP 60(b) motion to undo it. The Court concluded that being a grandparent, by itself, does not give someone a legal interest in a grandchild's adoption sufficient to challenge it. Nevada's adoption statutes do not list grandparents among those entitled to notice or to object, and grandparents generally do not have a constitutional right to intervene in an adoption absent something extra, like a pre-existing court-ordered visitation right. The Court also held that simply having filed a guardianship petition that had not yet been decided created only a "prospective" interest — a possible future interest — which is not enough to confer standing to attack an adoption decree. Because Angela and Randall were not parties to the adoption, were not in privity with a party, and had no legal interest that was directly affected by the adoption decree, the Supreme Court held the district court should not have entertained their motion. The adoption stands.

This case involves a custody fight between a father (Justin Blount), his wife (Stephanie Blount), and the children's paternal grandmother (Paula Blount). The children's biological mother, who was a member of the Hualapai Tribe, had originally been awarded temporary custody by the Tribal Court in Arizona. After she passed away, the Tribal Court returned custody to Justin, and the children moved to Nevada with him and Stephanie in 2017. In 2019, a Nevada court entered a decree of adoption declaring Justin and Stephanie the children's legal parents. The grandmother, Paula, then went back to the Tribal Court in late 2019 seeking grandparent visitation. After a hearing that Justin did not attend, the Tribal Court entered an order in January 2020 granting joint custody to Paula and Justin. Paula then sought to "register" that Tribal Court order in Nevada - a procedure under Nevada law that makes an out-of-state custody order enforceable here. Justin's attorney was served with notice of the registration request on April 6, 2020. Under Nevada's version of the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), a person who wants to fight registration of an out-of-state custody order has 20 days to request a hearing. Justin filed his challenge on day 24 - four days late. Stephanie filed hers months later. The district court confirmed the Tribal Court order, and Justin and Stephanie appealed. The Nevada Supreme Court affirmed. The court held that the 20-day deadline in NRS 125A.465 means what it says: if you don't challenge registration within 20 days of receiving notice, the foreign order is automatically registered "as a matter of law," and you lose the ability to raise challenges that you could have raised during that 20-day window. Because Justin and Stephanie missed the deadline, the court did not reach the merits of their objections to the Tribal Court order - including their arguments that the Tribal Court lacked jurisdiction, that another order superseded it, and that proper notice was not given. The court also noted that Stephanie was not legally entitled to notice of the registration request because the Tribal Court had never awarded her custody or visitation. The court expressly noted that the 2019 Nevada adoption decree was not before it on appeal and that the UCCJEA does "not govern adoption proceedings." The court acknowledged that other Nevada statutes addressing adoption and post-adoption visitation could potentially conflict with the registration statute, but because the parties did not raise those statutes, the court expressed no opinion on the issue.