Nevada family-law case summaries

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to the Tribal Court order - including their arguments that the Tribal Court lacked jurisdiction, that another order superseded it, and that proper notice was not given.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.