Nevada family-law case summaries

This case began as a divorce. After the trial court entered a divorce decree, the wife appealed to the Nevada Supreme Court. While the appeal was pending, her lawyer was permitted to withdraw - meaning the lawyer was allowed to stop representing her. On November 24, 2025, the court gave her 28 days to either hire a new lawyer, ask for more time to find one, or tell the court in writing that she would represent herself. She did not respond. On January 6, 2026, the court gave her another 14 days to take one of those steps and warned her that if she did not, her appeal could be dismissed. She still did not respond or contact the court. The husband then asked the court to dismiss the appeal because she was no longer participating. She did not file any response to that motion either. The Nevada Supreme Court concluded that she had abandoned her appeal and dismissed it. As a practical matter, that means the divorce decree from the lower court stands, and the Supreme Court will not review the merits of her challenge.

Francine Curcio and Ernest Hemmings divorced in 2013. They share a daughter, H.H., born in 2009. Under the divorce decree, Curcio had primary physical custody and Hemmings had parenting time. In 2021, after mediation, the parties agreed that Curcio would keep primary physical custody and Hemmings would have parenting time from every Friday through Monday. In December 2024, Curcio asked the court to give her sole physical custody. She said that during a recent visit, Hemmings slapped a snack out of H.H.'s hand and that H.H. no longer wished to see him. She later added that H.H., then 15, had lost 30 pounds and reported that Hemmings was restricting her food and making inappropriate comments about her body. Hemmings opposed and filed his own request to change custody, arguing Curcio was interfering with his relationship with H.H. and that the snack incident had been exaggerated. The court treated the matter as more of a therapeutic problem than a legal dispute. It scheduled status checks (brief hearings to check on progress) rather than a full trial. The parties first agreed to joint therapy sessions with one therapist (Kendra Meza), who declined to participate in the legal case and referred them to Dr. Donna Willburn. Dr. Willburn met with H.H. and Hemmings three times and recommended a week-on, week-off custody schedule. At a May 2025 hearing that was scheduled only as a status check, the district court announced it would change custody to match Dr. Willburn's recommendation, adopting the week-on, week-off schedule and directing Hemmings's attorney to prepare a request for attorney fees and costs. Curcio appealed. The Court of Appeals agreed with her that the district court should not have changed custody without first holding an evidentiary hearing - a hearing where witnesses testify and evidence is presented - and without making written findings explaining how the change served the child's best interest. Because the parties' accounts directly conflicted, the court explained that the district court needed to gather evidence and resolve those conflicts itself rather than rely solely on the therapist's recommendation. The Court of Appeals also addressed a statement in the district court's order suggesting the parties had presented a "Parenting Agreement." After ordering additional briefing, the appellate court concluded there was no support for the idea that such an agreement existed; in fact, Hemmings's own attorney admitted at the hearing that there was no parenting agreement and that the parties were before the court on competing motions. The Court of Appeals reversed the custody modification and sent the case back for a proper evidentiary hearing and findings. It dismissed the part of the appeal dealing with attorney fees because the district court had not yet entered a written order awarding fees, so there was nothing final to review on that point. The court noted, however, that when a judgment is reversed, any accompanying fee and cost award is necessarily vacated.

Vick and Anjena Gill married in 2020 and had a son, K.G., who was born in Las Vegas in April 2023. About a month after K.G.'s birth, Anjena and the baby traveled to Canada for a funeral. They ended up staying longer than planned, in part because the family's Nevada home had a major water leak and Anjena found temporary work in Canada. Vick remained in regular contact, visited, and the couple even discussed having more children. At some point the marriage broke down. In November 2023, Anjena filed for custody of K.G. in a Canadian court. Vick responded by filing a Hague Convention petition in Canada seeking the child's return to Nevada; the Canadian court denied that petition, finding that K.G.'s "habitual residence" was Canada. Vick lost his appeal of that ruling. In May 2024, Vick filed for divorce in Nevada and asked the Nevada court for custody and child support. The Nevada district court refused, saying it did not have "home state" jurisdiction over the child and that a lot of litigation had already happened in Canada. Vick appealed to the Nevada Supreme Court. The Nevada Supreme Court reversed. Under the UCCJEA (Nevada's version is in NRS Chapter 125A), a state is a child's "home state" if the child lived there with a parent for at least six consecutive months before the case was filed, and that period includes any "temporary absence" from the state. The Court concluded that K.G.'s time in Canada from May to November 2023 was a temporary absence: Anjena originally went for a funeral intending to return, communicated frequently with Vick, discussed expanding the family, and the prolonged stay was due to a home repair and short-term work. The Hague proceeding itself found that Anjena did not form an intent to remain in Canada until November 2023. So for jurisdictional purposes, K.G. is treated as having lived in Nevada until November 6, 2023 - less than six months before Vick's May 3, 2024 filing. That makes Nevada the home state. However, the Court did not order Nevada to keep the case. It explained that the earlier Hague ruling - finding Canada to be K.G.'s habitual residence - is entitled to "considerable weight" and that international practice generally directs custody decisions to the country of habitual residence. Under NRS 125A.365(1), a Nevada court may decline jurisdiction if another forum is more appropriate. The Court said deferring to Canada "may ultimately be appropriate," but it would be premature to do so now because: (1) the Canadian court has not yet decided whether it has jurisdiction; and (2) the parties have not had a chance to brief the issue in Nevada. The Court instructed the district court on remand to try to hold a UCCJEA-style conference with the Canadian court, take briefing, and apply NRS 125A.365 to decide whether Nevada or Canada is the more appropriate forum. On the child support claim, the Court noted that custody and support typically travel together, and instructed the district court to exercise jurisdiction over both pending its decision on whether to defer to Canada. The Court did not consider Vick's separate complaint about attorney fees because the record showed no fee award had actually been entered.

Adynes Proenza Chavez and Jose L. Ramos Ventura were once married and have one child together, a boy born in December 2021 (referred to in the opinion as L.R.P.). When they divorced in February 2025, the court gave them joint legal and joint physical custody, with the child living with Chavez during the week and with Ventura on weekends. In March 2025, shortly after the divorce, Chavez asked the court to change that arrangement and give her sole legal and sole physical custody. She said that her 12-year-old daughter from a previous relationship had accused Ventura of sexually abusing her. According to Chavez, the alleged abuse happened when her daughter was 11, occurred more than once, and took place in front of the couple's young son, who was two at the time. Chavez said she was afraid Ventura might do the same thing to their son. She stated that, as a result of these accusations, Clark County Child Protective Services (CPS) had an open case and the Las Vegas Metropolitan Police Department (LVMPD) had an open investigation. She included the CPS investigation number, the LVMPD event number, and the name of the investigating detective. She also obtained a temporary protection order (a court order issued on March 14, 2025, that gave her temporary custody of the child and gave Ventura no parenting time until it was scheduled to expire on April 28, 2025). Ventura filed papers opposing the change. He said he wanted to keep the existing schedule, but he did not respond to the abuse allegations themselves. Without holding a hearing, the district court denied Chavez's request. The court acknowledged the allegations that Ventura was under CPS investigation for alleged abuse of the daughter. But it concluded that, even if those allegations were true, they did not show a substantial change in circumstances affecting the welfare of the three-year-old boy, and did not show that changing custody would be in his best interest. The court also found that Chavez had not shown "adequate cause" to justify holding a fuller evidentiary hearing (a hearing where evidence and testimony are presented). It ordered the parties to go back to the original schedule once the protection order expired. Chavez appealed. The Court of Appeals reversed. It explained that when a parent asks to change physical custody, the trial court must hold an evidentiary hearing if the parent shows "adequate cause" for one — meaning the parent presents enough facts to make a preliminary ("prima facie") case for changing custody. Importantly, in deciding whether to hold such a hearing, the court must assume the parent's specific allegations are true. Accepting Chavez's allegations as true — the new CPS and LVMPD investigations, the protection order, and the claim that abuse occurred in front of the child after the divorce decree — the appeals court concluded these allegations could show a substantial change in circumstances and could show the child's best interest would be served by a change. Because Ventura did not conclusively prove the allegations were false, a hearing was needed. The Court of Appeals was careful to say it was not deciding whether Chavez should win. It only decided that the district court should have held an evidentiary hearing. It also noted that the district court has broad discretion to decide what form that hearing should take. The case was sent back to the district court for further proceedings.

This is a one-paragraph administrative order closing out an appeal. Raquel Arellano had filed an appeal with the Nevada Supreme Court in a case involving Shawn Ramos, originating from the family division of the Washoe County District Court. Before the court considered the merits, Arellano asked the court to dismiss her own appeal, and the other side did not oppose that request. The Nevada Supreme Court granted the request and closed the case. No remittitur was issued, and the court did not rule on any underlying legal issue. For readers, this means the appellate court did not decide who was right or wrong in the dispute. It simply allowed the appealing party to withdraw the appeal, which is a routine procedural step parties may take when they no longer wish to pursue review.

Luba and Enrique divorced in 2021 and agreed to share custody of their daughter, I.G., on an alternating weekly schedule. Their divorce decree required them to confer with each other about the child's health care and gave each parent annual vacation time, with a detailed written itinerary required for out-of-state trips. In March 2023, two disputes arose. First, Luba rescheduled I.G.'s dental appointment - originally set during Enrique's week - to fall during her own week, without asking Enrique first. Second, Enrique planned a family trip to Mexico with I.G., but two days before departure Luba filed a motion to stop the trip, citing safety concerns about the route and destinations. After an off-the-record phone conference with the judge and failed negotiations between the lawyers (Luba wanted advance copies of border-crossing tickets; Enrique refused to provide them), Luba refused to hand I.G. over, and the child missed the trip. Enrique then asked the court to hold Luba in contempt - a finding that a person disobeyed a court order - and to give him primary physical custody. After a two-day evidentiary hearing, the district court found by clear and convincing evidence that Luba "willfully detained" I.G., which under Nevada law counts as an act of "abduction" for custody purposes and creates a presumption against giving the abducting parent custody. The court found Luba overcame that presumption, but it still concluded the abduction was a substantial change in circumstances and that it was in I.G.'s best interest for Enrique to have primary physical custody. It also held Luba in contempt for both the withholding and the dental appointment change ($500 each) and awarded Enrique $767.50 in attorney fees for responding to a reconsideration motion. The Nevada Court of Appeals affirmed most of the district court's rulings. It rejected Luba's argument that "willfully" in the abduction statute, NRS 200.359(1), requires proof of "specific intent" - that is, an intent to break the law or harm the other parent - holding instead that it requires only an intent to do the act itself. It also held that a single act of withholding a child can qualify as an abduction, and that no criminal conviction is required before a family court can find an abduction occurred. The court found the district court's best-interest findings were supported by the evidence and declined to second-guess the trial judge's credibility calls. The Court of Appeals did, however, reverse one piece: the contempt finding for changing the dental appointment. Because the divorce decree said inconsistent things - requiring conferral on "all matters" regarding health care in one place but only "all important matters" in another, and never saying when conferral had to happen - the decree was too ambiguous to support a contempt finding on that count. The $500 sanction tied to that count was reversed. The contempt finding for withholding I.G., the custody modification, and the attorney fee award all stand.

This case involves a dispute over custody of a child. After the trial court (the district court) entered a custody decree, Carmen Barnes tried to appeal that decree to the Court of Appeals. Before an appeals court can decide an appeal, it must have "jurisdiction" - the legal authority to hear the case. One requirement for jurisdiction in this kind of case is that the lower court's order must be "final," meaning it has wrapped up all the issues and left nothing more for the court to decide later. Here, the appeals court found that the custody decree was not final. The decree gave one party, Oresko, primary physical custody of the child, but it attached conditions that had to be met first. Specifically, Oresko was directed to undergo substance abuse testing and could not obtain custody until he had completed three weeks of testing without any positive results. The decree also directed Oresko to obtain suitable housing for himself and the child before the child could live with him. Because Oresko still had to satisfy these conditions before the district court could make a final custody determination in his favor, the appeals court concluded the decree did not resolve everything and was therefore not a final order that could be appealed. As a result, the court held it lacked jurisdiction and dismissed the appeal. The court noted that, in the meantime, the decree itself provides that Barnes will remain the de facto custodian until Oresko meets the necessary requirements to take over as primary custodian. The court also directed its clerk to amend the caption on the court's docket to match the caption on the order.

When someone files an appeal in Nevada, the rules require that the notice of appeal be served on the other parties in the case, and that proof of that service be filed with the court. In this case, Angelica Baker filed a notice of appeal, but she did not include proof that she had served the other side. The Nevada Supreme Court notified her of the problem on November 4, 2025, and gave her 14 days to provide the missing proof of service, warning that the appeal could be dismissed if she did not. When she did not respond, the court issued a second order on December 5, 2025, again giving her 14 days and again warning of dismissal. She still did not respond. Because the appellant did not comply with either directive, the court dismissed the appeal. The order does not address the merits of the underlying dispute between Baker and Thompson.

This case involves a dispute over temporary emergency orders about child custody. One parent, Tiffanee Bruchu, asked the Nevada Court of Appeals to step in on an emergency basis and overturn those orders. She filed the request herself, without an attorney, using a tool called a writ of mandamus - a court order that directs a lower court or official to do something the law requires, or that corrects a decision made in an arbitrary or unreasonable way. The court explained that whether to even take up a request for this kind of extraordinary relief is entirely up to the court's own discretion, and that the person asking for it carries the burden of showing the relief is justified. After reviewing the petition and the documents filed in support of it, the court concluded that Bruchu had not shown that this extraordinary relief was warranted. The court therefore denied the petition. The opinion does not explain the underlying facts of the custody dispute or analyze the specifics of the emergency orders.

This is a short procedural order, not a ruling on the merits of any custody or fee dispute. Haleigh Isbill filed an appeal in the Nevada Supreme Court without an attorney, challenging a Clark County family court order that had denied her child custody motions and her request for attorney fees and costs. When someone files an appeal, the Supreme Court requires certain paperwork early in the case: a transcript request form (or a statement that no transcript is needed), a docketing statement (a basic information form about the case), and an opening brief (the document explaining why the lower court got it wrong). On November 14, 2025, the court told Isbill when each of those documents was due. She did not file the transcript form or the docketing statement on time. On December 15, 2025, the court gave her a second deadline of December 29, 2025, and warned that missing it could lead to dismissal. She still did not file those documents, and she also did not file her opening brief by its January 13, 2026 deadline. Concluding that she had abandoned the appeal, the Supreme Court dismissed it. The order does not address the substance of the custody or fee dispute.

Edward Pitts asked a Clark County family court to change an existing order about child custody, visitation, and child support. The family court judge denied his request. Pitts then appealed that denial to the Nevada Supreme Court, representing himself without a lawyer. When someone files an appeal in Nevada, the Supreme Court requires certain paperwork early in the process - things like a form telling the court whether transcripts of the lower-court hearings will be ordered, a "docketing statement" describing the case, and an opening brief explaining why the lower court got it wrong. On November 14, 2025, the Supreme Court told Pitts when each of these items was due. He missed the deadlines. On December 16, 2025, the court gave him another 14 days and warned him that if he still did not file the missing documents, his appeal could be thrown out. He did not file them. He also did not file his opening brief, which was due January 13, 2026, and he did not contact the court at all. Concluding that Pitts had abandoned the appeal, the Supreme Court dismissed it. The family court's order denying his motion to modify custody, visitation, and support remains in place.

This is a brief administrative order ending an appeal in a child custody case. The person who filed the appeal, Terrance Bacote, asked the Nevada Supreme Court to drop his own appeal. The court agreed and dismissed it. The court also took one additional housekeeping step. On January 14, 2026, it had ordered the district court to enter a written order on a motion to reconsider that was pending in the lower court. Because the appeal is now over, the court vacated (cancelled) that portion of its earlier order. The order does not address the underlying merits of the custody dispute.

This is a child custody appeal that the Nevada Supreme Court threw out before reaching the merits, because the appeal was filed too late. The father, Eric Perreira, was trying to challenge a Clark County family court order entered on October 6, 2025, that decided custody of a minor child. Under Nevada's appellate rules, a party who wants to appeal generally has 30 days from the date the other side mails notice that the order has been entered. Notice was mailed on October 7, 2025, but Mr. Perreira did not file his notice of appeal in district court until December 11, 2025 - well beyond the 30-day window. Because the deadline to appeal is jurisdictional - meaning the Supreme Court has no power to hear an appeal filed after it expires - the court dismissed the case. The court noted, however, that Mr. Perreira has a separate pending appeal (Docket No. 91613) that challenges the same October 6, 2025, order, and that he can pursue his arguments about that order in that other appeal.

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.

Kathryn and Brian Mead divorced in 2007 and had three children, all of whom are now adults. In February 2024, Brian's house burned down, and Kathryn then asked the court to give her primary physical custody of their youngest child, R.M., who was still a minor. The court instead awarded the parents joint legal and physical custody and set Brian's child support amount. Kathryn appealed that 2024 decision, and the Court of Appeals affirmed it. After that appeal concluded, Kathryn filed a new motion in February 2025. By then R.M. had turned 18 in January but had not yet graduated from high school (graduation was set for May). Kathryn again asked the court to recognize her as the primary physical custodian and to recalculate child support. Her main argument was that the court's earlier 2024 order had contained legal mistakes and was not properly supported, including that the court failed to treat her as R.M.'s "de facto" (in-practice) primary custodian after the fire. She said she was struggling financially and believed Brian had hidden his true income at the 2024 hearing. However, she did not attach an updated Financial Disclosure Form, and she gave no specific details supporting the claim that Brian had misrepresented his income. Brian did not file any response. The district court denied her motion without holding a hearing. It found that the children, including R.M., were now adults; that it had recently decided custody in the 2024 order (which had been affirmed on appeal); that Kathryn had not provided an updated financial form; and that she had not shown a "substantial change in circumstances" that would justify revisiting custody or support. On appeal, the Court of Appeals affirmed. First, it explained that it had already considered and rejected Kathryn's arguments about the 2024 order in her earlier appeal, so a legal principle called the "law of the case doctrine" prevented her from relitigating those same issues. Second, the court addressed Kathryn's claim that she was entitled to a hearing. The court noted that R.M. is now 18 and has graduated, which would normally make the custody question moot (no longer a live issue). But because Kathryn also sought to modify child support for the period between R.M.'s 18th birthday and his graduation, the court concluded the custody portion was not moot. On the merits, the court explained that to get a hearing on a request to change custody, a parent must show "adequate cause" by presenting a basic ("prima facie") case that there was a substantial change in circumstances affecting the child and that changing custody would serve the child's best interest. Importantly, the change must generally have happened since the last custody decision. Kathryn's motion relied on alleged errors in the prior hearing and on the February 2024 fire, both of which predated the 2024 order. Because she did not point to anything new that happened after the 2024 order, her motion was "repetitive," and she was not entitled to a hearing. Third, the court applied similar reasoning to child support. A court may review support based on changed circumstances, but here the court had recently entered a support order and made findings about the parents' income, Kathryn did not provide an updated financial form, and she relied on the same pre-2024 events. The court concluded she did not show changed circumstances, so denying the support motion without a hearing was not an abuse of discretion.

This was an appeal by Deniece Vaughn, representing herself, from a Clark County family court decision about child custody. To move an appeal forward in the Nevada Supreme Court, the person appealing must file certain documents on a schedule - including a form telling the court whether transcripts of the lower-court hearings are being ordered, a "docketing statement" (a form summarizing the appeal), and an opening brief (the written argument explaining why the lower court got it wrong). On September 26, 2025, the Supreme Court sent Vaughn a notice telling her when each of these documents was due. When she did not file the transcript request form or the docketing statement, the court issued a second order on November 3, 2025, giving her another 14 days and warning that the appeal could be dismissed if she did not comply. Vaughn still did not file those documents, did not file the opening brief that was due November 25, 2025, and did not otherwise contact the court. Concluding that Vaughn had abandoned the appeal, the Supreme Court dismissed it. The dismissal does not address the merits of the underlying custody dispute; it ends this particular appeal because the procedural steps required to pursue it were not taken.

The parties to this child-custody appeal settled their dispute while the case was pending before the Nevada Supreme Court. They signed a settlement term sheet and prepared a proposed order for the district court (the lower court) to enter. Both sides then filed motions in the Supreme Court on the same day, but asking for different things. Appellant asked the Supreme Court to dismiss the appeal conditionally, meaning the appeal would go away unless the district court refused to enter the agreed-upon order, in which case she could revive the appeal. Respondent, by contrast, asked the Supreme Court to send the case back ("remand") so the district court could clarify the parties' memorandum of understanding, or alternatively to set the settlement aside and keep the appeal going. The Supreme Court explained that any dispute over what the settlement actually means has to be raised first in the district court. Under the appellate rule governing remands during appeal, the Supreme Court can remand only if the district court has signaled it would grant relief or that there is a substantial issue. Respondent did not show either, so the court denied his remand request. The court also denied appellant's request for attorney fees for opposing that motion. The court then granted appellant's request to dismiss the appeal and sent the case back to the district court so it can take whatever steps are needed to carry out the settlement. If the district court refuses to grant the relief the parties want, appellant has 30 days from that denial to ask the Supreme Court to reinstate the appeal.

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.

Christina S. and Joshua S. were never married but share two minor children. Christina asked the family court to terminate Joshua's parental rights - that is, to legally end his status as the children's father. The district court refused, finding that ending Joshua's parental rights would not be in the children's best interest. Christina appealed, and the Nevada Supreme Court affirmed the district court's decision. To terminate parental rights in Nevada, a parent must prove two things by "clear and convincing evidence" (a high standard, more than the usual civil burden but less than the criminal "beyond a reasonable doubt"): (1) that there is at least one ground of "parental fault," and (2) that termination is in the children's best interest. Because Christina lost on the second prong, the appellate court did not need to reach the first. The court acknowledged that Joshua had serious problems. He was incarcerated at the time of trial for abusing one of the children and Christina, he had a history of domestic abuse, and he continued to minimize that history. On the other hand, the district court found that Joshua had successfully completed supervised and unsupervised visits before incarceration, was assessed as low-risk to reoffend, and was a first-time parent. A licensed clinical social worker, John S. Pacult, evaluated Joshua and concluded that reunification - subject to conditions - was preferable to termination. Christina also already has sole legal and physical custody, so Joshua poses no immediate risk to the children. Christina raised three issues on appeal. First, she objected to Pacult's expert testimony, but the Supreme Court held she could not complain on appeal because she had stipulated to his designation as an expert and did not object when his report was admitted. Under the "invited error" doctrine, a party cannot complain about errors she helped cause. Second, she argued the district court got the best-interest analysis wrong. The Supreme Court disagreed, finding "substantial evidence" supported the district court's careful weighing of the evidence, and noted that Nevada's termination statute is meant to protect children, not punish parents. Third, she argued the district court should have ordered Joshua to pay her attorney fees because he allegedly filed a motion in bad faith to remove her lawyer. The Supreme Court found no abuse of discretion in the district court's conclusion that neither party had litigated unreasonably or vexatiously. The Supreme Court also declined Christina's request to reconsider a recent decision (Matter of L.R.S.) holding that certain statutory considerations and presumptions in NRS 128.107 and NRS 128.109 do not apply to private (parent-versus-parent) termination cases.

Michael Martinelli and Michelle Lucero Del Real were in a romantic relationship that began in 2013, shortly after Del Real's son was born. Martinelli is not the child's biological father. The relationship ended in 2022 after, according to the opinion, Martinelli committed an act of domestic violence against Del Real in the presence of the child. In 2022, Martinelli filed a petition asking the court to grant him "nonparent visitation" - that is, court-ordered time with a child by someone who is not the child's parent. He claimed he had lived with the child, had a meaningful relationship with the child, acted as a de facto father, and that Del Real had unreasonably refused to let him see the child. Del Real opposed the petition. The trial court scheduled an evidentiary hearing (a hearing where witnesses testify and evidence is presented) and set deadlines for discovery (the pretrial process of exchanging information). Before the hearing, Martinelli asked the court to stop Del Real from mentioning his arrests and domestic-violence incidents, and asked to reopen discovery to gather more information about the child's schooling and medical issues. Del Real, by then represented by free (pro bono) lawyers, opposed those requests, and separately asked the court to declare Martinelli a "vexatious litigant" - someone who misuses court proceedings to harass another person. The court denied Martinelli's two pretrial motions and held the evidentiary hearing, giving each side 90 minutes. Witnesses included two of the child's teachers, a family friend, and both Martinelli and Del Real. Del Real testified about an incident in which Martinelli slammed a door into her in front of the child (a video of this was shown to the court), about verbal abuse, and about Martinelli being arrested in Arizona for driving under the influence while the child was in the car. She also described the child's chronic medical condition (chronic pancreatitis) requiring frequent hospitalizations. The child's recorded interview indicated the child did not wish to visit Martinelli. The court ruled against Martinelli. Under Nevada law, when a parent has denied visitation, there is a legal presumption that giving visitation to a nonparent is not in the child's best interest, and the person seeking visitation must overcome that presumption with strong proof ("clear and convincing evidence"). The court found Martinelli did not meet that burden, citing the lack of positive emotional ties, his history of abusive behavior and addiction, the conflict in the relationship, and the child's stated preference not to continue a relationship with him. The court also found that Martinelli had filed the case to harass Del Real and had abused the discovery process, declared him a vexatious litigant, and ordered him to pay $5,000 in attorney fees to the Legal Aid Center of Southern Nevada. After Martinelli filed a motion to set aside the judgment and a motion for a new trial, the court denied both and ordered an additional $500 in attorney fees. On appeal, the Court of Appeals upheld every part of the trial court's decision. It found the trial court acted within its discretion on the discovery and evidence rulings, that substantial evidence supported the denial of visitation, that Martinelli had in fact been given a chance to oppose the vexatious-litigant request (he filed a written opposition), and that he had not shown the judge was biased.

This is a procedural dismissal, not a decision on the merits of the underlying child custody dispute. When someone files an appeal in Nevada, they must also file a document called a "case appeal statement" - a short form that gives the court basic information about the case. Saxon Harding filed a notice of appeal but did not include this required statement. The Nevada Supreme Court gave him two chances to fix the problem. On November 4, 2025, the court issued a notice telling him to file the case appeal statement within 7 days and warned that not doing so could lead to sanctions. When he still had not filed it, on November 14, 2025, the court issued a second order giving him another 7 days and warning that failure to comply would result in dismissal of the appeal. Because the case appeal statement was still not filed, the court dismissed the appeal. The order does not address the merits of the custody dispute between the parties.

This is a procedural dismissal, not a ruling on the merits of the underlying child custody dispute. When someone files an appeal with the Nevada Supreme Court, they generally must pay a filing fee. If they cannot afford the fee, they can ask to proceed "in forma pauperis" - a legal term meaning the court allows the case to go forward without payment because of financial hardship. Here, the appellant filed his appeal but did not pay the filing fee. The court told him he had 14 days to either pay or properly request a fee waiver. He filed a fee-waiver motion, but he filed it in the wrong court - it must first be filed in the district court (the lower court), not the Supreme Court. The Supreme Court denied that motion without prejudice (meaning he could try again the right way) and gave him 30 more days to either file the motion in district court and provide proof, or pay the fee. He did neither. Because of that, the Supreme Court dismissed the appeal.

When someone files an appeal in Nevada, the rules require them to serve (formally deliver) the notice of appeal on the other parties and then prove to the court that they did so. In this child-custody appeal, the appellant filed her notice of appeal but did not include the required proof that she had served it on the other side. The Supreme Court gave her multiple chances to fix the problem. On August 27, 2025, the court told her she had 14 days to file the missing proof of service. On September 22, 2025, after she still had not done so, the court issued another order giving her another 14 days and warning that the appeal could be dismissed. On October 2, 2025, she filed a proof-of-service document, but it was missing required information - the date and manner of service and the names of the people served - so on October 3, 2025, the court struck that filing and gave her 7 days to file a corrected version. On November 13, 2025, after she still had not corrected it, the court issued yet another order giving her 7 more days and again warning that the appeal would be dismissed. She did not comply. The court therefore dismissed the appeal. The dismissal is based solely on the failure to perfect service paperwork; the order does not address the merits of the underlying custody dispute.

This is a very short procedural order, not a decision on the merits of any legal dispute. The case involved a minor child, identified only by initials (L.G.), and the State of Nevada. The parties reached an agreement - called a stipulation - to end the appeal. Based on that agreement, and finding "cause appearing," the Nevada Supreme Court dismissed the appeal. The court did not rule on who was right or wrong on any underlying issue; it simply closed the appeal as the parties requested. The court also directed that each side pay its own costs and attorney fees. Finally, because the appeal was being dismissed, two motions that had been filed earlier (on October 8 and October 29, 2025) were denied as moot - meaning there was no longer any live reason to decide them.

This is a child custody matter that never reached the merits on appeal. The father, Ricardo Underwood, representing himself, tried to appeal two orders from a Washoe County family court judge: a "pickup order" and an "order for return of minor child." Those are interim orders family courts use to secure the physical return or transfer of a child while a custody case is ongoing. The Nevada Supreme Court did not decide whether the family court was right or wrong about the child. Instead, it concluded it had no power to hear the appeal at all. In Nevada, you cannot appeal every order a trial court issues. You can appeal only when a statute or court rule specifically says that type of order is appealable. The Supreme Court found that no statute or rule allows an appeal from the kinds of orders Mr. Underwood was challenging, so it dismissed the appeal for lack of jurisdiction.

Adam and Sandy Goldstein married in April 2011 and went through divorce and child custody proceedings beginning in 2019 after Sandy filed for divorce and custody. The case was split into two parts (a "bifurcated" trial): a custody trial in May 2021 and a financial trial in September 2021. In May 2022, the district court awarded Sandy primary physical custody and permission to move with the children to Colorado, finding that Adam had opposed the relocation in bad faith. The court also found that Adam had made unsubstantiated claims that Sandy was an alcoholic, withheld parenting time from Sandy, influenced one of the children's testimony, and made an unsubstantiated claim of educational neglect to gain an advantage. The court issued a separate divorce decree on financial issues that included alimony for Adam. Adam did not appeal any of those orders. After those rulings, both parties asked for attorney fees. Sandy requested fees under a Nevada statute and argued that Adam's bad-faith conduct drove up the cost of the litigation. The district court denied Adam's request and granted Sandy's. The court reasoned that the attorney fees were a "community obligation" (a shared marital debt) and that it could divide that debt unequally because Adam had engaged in improper litigation tactics that wasted shared marital assets. After Sandy submitted billing records seeking $194,861.25, the court reduced that figure—cutting certain "block billing" entries it could not allocate, reducing the custody-trial fees by 30 percent, and reducing the total by another 20 percent for time spent supervising a junior attorney—and awarded $124,627.12. On appeal, the Court of Appeals agreed with Adam on one point: the attorney fees should not have been treated as a community obligation. Drawing on prior Nevada cases, the court explained that debt incurred after spouses separate, and not for the benefit of the marriage, is not community debt. Because these fees were incurred after separation and did not benefit the community, the district court could not use that as the basis for the award. However, the Court of Appeals affirmed anyway. Under the rule that an appellate court will uphold a lower court's decision if it reached the right result even for the wrong reason, the court looked to a different legal basis that Sandy had raised below: a statute allowing fees against a party who brings or maintains claims without reasonable grounds or to harass the other party. The district court had already made detailed written findings that Adam pursued frivolous and bad-faith positions—on relocation, the alcoholism allegation, withholding the children, and influencing a child's testimony. Importantly, the Court of Appeals noted that Adam, in his reply brief, conceded that those findings were the type that would support a fee award under that statute. Because Sandy was the prevailing party and the findings supporting a fee award were backed by substantial evidence, the court held the fee award could stand. The court also rejected Adam's arguments that the district court ignored the income disparity between the parties and that the amount awarded was unreasonable. The record showed the court did consider income—finding the parties had essentially equal net income after accounting for Sandy's rental and travel costs versus Adam's low housing expenses, and noting Adam received alimony—and that the court applied the established factors for setting a reasonable fee amount and explained its reductions.

A father, Seth Gutierrez, tried to appeal a family court decision from Clark County that changed the custody and child support arrangements involving him and Cassandra Gutierrez. He filed the appeal himself, without a lawyer. When someone files an appeal in Nevada, the Supreme Court requires certain paperwork early in the process. Two of those documents are a transcript request form (or a statement that no transcript is needed) and a docketing statement (a form that gives the court basic information about the case and the issues on appeal). According to the order, the Supreme Court told the appellant on July 25, 2025, to file these documents within set deadlines. When he did not, the court issued a second order on September 3, 2025, giving him a new deadline and warning that the appeal could be dismissed. He still did not file. The court tried again on October 21, 2025, with another deadline of November 4, 2025, and another warning. The documents were never filed. Because the appellant did not submit the required paperwork despite multiple warnings, the Supreme Court concluded that he had abandoned the appeal and dismissed it. The underlying district court order altering custody and support therefore stands.

J.B. was taken into protective custody two days after his birth and placed by DFS with Becky and Jay Whipple, a "fictive kin" placement (caregivers treated as family even though not biologically related). After paternity was established, the district court at one point ordered J.B. placed with his paternal grandfather. The Nevada Supreme Court reversed that placement in 2024. After further proceedings, the district court held an evidentiary hearing and placed J.B. with the Whipples. But as part of that order, the judge also gave the grandfather "significant" visitation rights and said those rights would continue even if the Whipples eventually adopted J.B. DFS asked the Supreme Court to order the visitation portion vacated. The Supreme Court agreed with DFS. Before reaching the merits, the court rejected an argument that DFS lacked "standing" (the legal right to bring the challenge). Because DFS had protective custody of J.B. and Nevada law gives DFS duties over a child's placement while in protective custody, DFS had a sufficient interest to challenge the order. On the merits, the court explained that the statute the district court relied on - NRS 125C.050 - allows grandparents to seek visitation only in specific circumstances, including when a parent's rights have been "relinquished or terminated." Here, although the parents had signed relinquishment paperwork, the relinquishments had not been finalized when the district court entered the order. Because no parental rights had actually been relinquished or terminated yet, the statutory trigger for grandparent visitation under NRS 125C.050 had not been met. The court held the district court therefore could not grant grandparent visitation under that statute and noted that any grandparent visitation in this posture would have to come through the district court's authority under NRS Chapter 432B. The court directed the district court to vacate the visitation portion of the placement order.

Lyka Grace Andres Peralta and Chyron Lee Talley married in Utah in December 2021, had a child together, and separated in October 2023 while Peralta was pregnant. Talley filed for divorce in November 2023. After their child, referred to as C.P., was born, the parties resolved most of their disputes through mediation, and Talley agreed that Peralta would have sole physical custody of the child. One issue remained: how much child support Talley would pay. At a July 2024 hearing, the district court calculated Talley's income but left out about $2,407.25 per month that the military pays him as a "basic allowance for housing," or BAH. During the hearing, Peralta noted that Talley appeared to earn more than the figure the court was using. The court and Talley discussed the BAH, and Talley told the court that the BAH was a housing benefit that he does not receive directly as income each month. The court accepted that explanation and used Talley's base pay of $3,066 to calculate child support, arriving at an award of $490 per month. The divorce decree and an amended decree both reflected that amount. Peralta appealed, arguing the court should have counted the BAH as part of Talley's income. The Court of Appeals agreed. It explained that Nevada's child support rules, found in the administrative code, specifically say that "gross income" includes military allowances, without limitation, and that no military housing allowance is exempted. Because the BAH is a military allowance, the court held it should have been included when figuring Talley's income. The Court of Appeals reversed the part of the decree dealing with child support and sent the case back to the district court to recalculate the award with the BAH included. The rest of the divorce decree stays in place. Peralta also asked the court to determine "arrearages" - past-due child support payments. The Court of Appeals declined to do that itself, explaining that while Talley will owe some additional amount once the support is recalculated, no past-due amount yet exists to be called an arrearage. The court left that determination to the district court, which is the factfinder.

Arturo Rendon and Lea Garcia married in 2012, had a child in 2017, and divorced in 2021. They had agreed to share joint legal and physical custody, eventually settling into a rotating week-on/week-off schedule that they managed without going back to court. In 2023, Lea — who works for the federal Bureau of Land Management (BLM) — was offered a job at the BLM office in Boise, Idaho. She gave Arturo written notice asking permission to move there with their child. She also conditionally accepted the Boise promotion and arranged a rental there. Arturo said no to the move. After that, Lea worked on-site in Boise during the weeks she did not have the child and traveled back to Nevada during the weeks she did. According to the opinion, she never actually relocated with the child before getting the court's permission. Lea then filed a motion in the district court asking to be allowed to move with the child and to be given primary physical custody. She argued the new job paid more and offered career advancement she couldn't get in Elko, and that schools in the Boise area rated higher than the child's school in Elko. Arturo opposed, arguing the pay increase wasn't large enough to justify uprooting the child's social life and that schooling, medical care, and other factors were roughly equal between the two places. The district court held an evidentiary hearing, hearing from both parents, a former coworker of Lea's, and Lea's mother. The testimony showed the parents cooperated well and were both deeply involved in the child's life, though there had been a few conflicts since the divorce. Lea emphasized her promotion, the lower cost of living in Boise, and better-rated schools. Arturo emphasized the child's need for stability, the child's friendships and good performance at her current school, his disagreement with the curriculum at a Catholic school Lea favored (Sacred Heart), concerns about moving the child away from Hispanic culture, and safety concerns about the highway between Boise and Elko used for custody exchanges. The district court granted Lea's motion, found she had met her legal burden under the relevant statutes, found the impending move was a substantial change in circumstances justifying a custody modification, and awarded her primary physical custody, subject to Arturo's parenting time. On appeal, Arturo raised three main points. First, he argued Lea didn't comply with the relocation statute because she effectively "relocated" part-time to Boise (without the child) before getting permission. The court declined to consider this because Arturo had not raised it in the district court. Second, he argued the court wrongly found that the move offered a real advantage to Lea and the child. Third, he argued the court wrongly found Lea's motives for moving were honorable. The court rejected both remaining arguments, explaining that it does not re-weigh evidence on appeal and that the district court's findings were supported by substantial evidence. The court also noted that Arturo had not challenged several of the other statutory factors, so those were treated as forfeited. The Court of Appeals affirmed.

Matthew Groves and Sarah Johnson married in 2019 and have two children, born in 2018 and 2019. Groves filed for divorce in 2022, and in September 2023 the court granted them joint legal and physical custody. While Groves was incarcerated from August to December 2023, the court temporarily gave Johnson primary physical custody, with the arrangement set to return to joint custody 30 days later. According to the opinion, after his release Groves had little if any contact with the children, who lived with Johnson. Johnson then moved with the children to Iowa. In March 2024, Johnson asked the court for full permanent custody and notified the court of her move. She said Groves had threatened her, had sent messages from jail saying it was best if he gave up his rights to the children, and had a history that included domestic violence against her. Groves opposed her request, saying she relocated without his consent. The court told Johnson to file a formal motion to relocate and told Groves to file a motion to modify custody if he wanted the children placed with him. Both did, and the court held an evidentiary hearing — a hearing where both sides testify and present evidence. At the hearing, Johnson testified that she relocated because she believed Groves' messages meant he wished to give up his parental rights, that Groves had threatened her and shown up at her Iowa home (leading her to obtain a protection order), and that the children were thriving in Iowa, where their medical needs were being treated. Groves testified that Johnson had a history of neglect and had been investigated by Child Protective Services. He also acknowledged that he had used methamphetamine for 25 years, was not seeking medical help for it, was living in a weekly motel, and did not know the children's needs because he had not been around them for over a year. After the hearing, the court granted Johnson's motion to relocate and denied Groves' request to modify custody. It found that staying in Iowa with Johnson was in the children's best interest, gave Johnson primary physical custody and sole legal custody, and awarded Groves one supervised video call per week for a year, which it found was the least restrictive parenting time available because it concluded Groves was not fit to have custody. On appeal, the Court of Appeals explained that custody and relocation decisions are reviewed for "abuse of discretion," meaning the appellate court does not substitute its own judgment but checks whether the trial court's findings are supported by "substantial evidence" — evidence a reasonable person would accept as adequate. The court noted that Johnson did move before getting consent or a court order, which ordinarily can expose a parent to consequences. But the district court found that Johnson credibly believed she had permission based on Groves' written statements, and that she was acting out of fear of domestic violence. The court found this did not amount to an abduction. The Court of Appeals concluded that the district court properly worked through the legal factors governing relocation and the best-interest factors, and that its findings were supported by substantial evidence. It pointed to the children thriving in Iowa, Johnson's improved circumstances, and Groves' criminal history, drug use, recent incarceration, and unstable living situation. Because the appellate court does not reweigh credibility or re-decide conflicting evidence, it affirmed the district court's decision in full.

Chandler Jensen and Natasha Peterson share one child, born in 2016. In 2023, Jensen filed for custody. While that case was pending, Peterson obtained a protection order against domestic violence based on encounters and messages she believed were threats. The extended protection order barred Jensen from threatening or harassing Peterson and required the parties to communicate only through an electronic parenting application, in messages that were reasonable in frequency and free of profanity. After a trial in August 2024, the district court awarded the parents joint legal and physical custody. At that time, the Division of Child and Family Services (DCFS) had an open investigation into Peterson and her boyfriend, and Peterson's parenting time was being supervised by her brother. The custody decree also ordered the parties to avoid abusive communications, including name-calling and foul language. Peterson later asked the court to change the custody arrangement. She pointed out that the DCFS investigation had ended with the allegations found unsubstantiated, that Jensen had been criminally charged with violating the protection order over an incident at a Boys and Girls Club, and that Jensen had continued sending her numerous disparaging and inappropriate messages after the decree, including repeated accusations that her boyfriend was a "pedophile." At an evidentiary hearing, Jensen testified he had not made such statements before the DCFS investigation began, but the court admitted—over his objection—a March 2024 message, sent well before the investigation, in which he called Peterson's boyfriend a "pedo." The parties also acknowledged Jensen had entered a no contest plea (a plea in which a defendant accepts conviction without admitting guilt) to charges stemming from the protection-order violation. The district court found several circumstances had substantially changed since the decree: the DCFS investigation—which had factored into the original joint custody decision—had concluded with the allegations unsubstantiated, and Jensen had violated both the protection order and the custody decree. The court also found, by clear and convincing evidence, that Jensen's harassing behavior amounted to domestic violence, which under Nevada law creates a rebuttable presumption—a starting assumption the parent can try to disprove—that joint physical custody is not in the child's best interest. The court found Jensen did not overcome that presumption, found his testimony not credible, and awarded Peterson primary physical custody. On appeal, the Nevada Court of Appeals affirmed. It held the text message was properly authenticated because Peterson explained why it was offered and provided corroborating evidence that Jensen wrote it. It held the district court's findings of changed circumstances and its best-interest analysis were supported by substantial evidence. The appellate court agreed with Jensen on one point: a no contest plea should not be used as evidence against a party in a civil case, so the district court erred by considering it. But the court concluded that error was harmless—meaning it did not change the outcome—because the district court's other extensive findings independently supported the modification. The court also held that the district court was permitted to consider harassing messages sent before the decree because that information had not been presented during the original custody proceedings.

A mother (or other interested party) named Shyeuna Vance tried to appeal a decision from a Clark County district court in a case involving a child, B.T. She filed her appeal paperwork without a lawyer. The Nevada Supreme Court can only hear appeals when a statute or court rule says it can. When the court checked the district court's records, it found problems with what Vance was trying to appeal. Her first notice of appeal said she was challenging an order entered July 31, 2025, but no order was entered in the district court on that date - the only thing filed that day was a report from the State about the child's permanency and placement. Her amended notice of appeal pointed to an order from August 21, 2025, but again, the district court did not enter any order on that day either. The closest actual order in the record was an "order after permanency hearing" entered August 6, 2025. The Supreme Court explained that no statute or rule allows an appeal from that kind of order. Citing its earlier decision involving a temporary guardianship, the court reiterated that temporary orders subject to periodic review are not the kind of orders an appellate court can review. Because there was no appealable order, the Supreme Court concluded it had no jurisdiction and dismissed the appeal. A pending motion to dismiss filed by another party and a motion to extend the briefing schedule were denied as moot.

This case involves a custody dispute between two parents, William Roberts and Catrina Andrino, over their seven-year-old child, W.R. In 2019, Andrino took the child to California without permission from Roberts or the court. As a consequence, the district court gave Roberts primary physical custody and limited Andrino to restricted visits. Andrino later returned to Nevada, lived with Roberts and the child for about a year, and then moved out at Roberts' request. She then asked the court for joint physical custody. The district court denied her request to share custody equally but did increase the time she could spend with W.R. Roberts appealed that increase. On appeal, Roberts argued that the court could not increase Andrino's visitation time without first finding that there had been a "substantial change in circumstances" affecting the child. The Nevada Supreme Court disagreed. The court explained that a substantial change in circumstances is required when shifting the actual custody label - for example, moving from primary to joint custody - but is not required when the court is simply adjusting the schedule of visits within an existing custody arrangement. For visitation adjustments, the test is the child's best interest. The Supreme Court reviewed the district court's findings: that Andrino now had stable employment in Nevada; that Roberts had been rigid in allowing parent-child time and used abusive language toward Andrino in ways that fueled conflict and that W.R. began to imitate; and that Andrino and W.R. share a close bond. The court found those findings supported by substantial evidence and concluded the district court did not abuse its discretion in awarding more visitation time to Andrino. The order was affirmed.

This case concerns a long-running custody dispute over one child, PJ, born in December 2018. The parents, Maila Likua and Paulino Gomez, married in 2016, lived together in Mesquite, Nevada, and separated in February 2022. Gomez filed for divorce, and a three-year custody battle followed. Early on, the court split the financial issues from the custody issues. In June 2022, the parents agreed to share legal and physical custody on an alternating three-week schedule until a custody trial could be held. After that trial, the court's first custody order (September 2023) gave the parents joint legal custody but gave Likua primary physical custody and permission to move PJ permanently to Molokai, Hawaii, while Gomez kept substantial parenting time. Gomez asked the court to reconsider; that request was denied, and he appealed. While that appeal was pending, Gomez asked the trial court for permission to change custody again, claiming Likua had taken PJ out of preschool and left Hawaii without telling him from April to mid-May 2024, and had concealed the child's whereabouts. Because of the seriousness of those allegations, the trial court issued what is called an "indicative ruling" (a signal that it would reconsider if given the chance), and with the supreme court's approval, the case was sent back to the trial court to address custody and relocation again. After a second custody hearing in November 2024, the trial court reversed course: it gave Gomez primary physical custody (with Likua keeping substantial parenting time) and allowed PJ to move back to Nevada. The court found that PJ's school attendance had dropped, his academic performance lagged behind his peers, and he had ongoing behavioral and focus problems. It also found that communication between the parents had broken down and that Likua had repeatedly interfered with Gomez's parenting time, including on Father's Day 2024, and had traveled with PJ without telling Gomez. On appeal, Likua first argued that the trial court unfairly placed extra duties and burdens on her as the primary custodial parent, violating her right to a fair process. The Court of Appeals disagreed, explaining that both parents fully briefed and argued their positions, presented evidence and witnesses, and made closing arguments. The court noted that, because Gomez was the one asking to change custody, he carried the burden of proof, not Likua. The three passages Likua pointed to simply described the ordinary obligations of a parent who shares legal custody — such as keeping the other parent informed of the child's location and honoring scheduled parenting time, including required FaceTime calls. Likua next argued that the trial court got the changed-circumstances and best-interest analyses wrong. The Court of Appeals applied a deferential standard, meaning it would not second-guess factual findings supported by enough evidence that a reasonable person could accept them. It found that PJ's academic decline and Likua's interference with Gomez's parenting time were enough to support a substantial change in circumstances, and that the trial court had made specific findings on each of the twelve best-interest factors, three of which favored modification. On relocation, the Court of Appeals made an unusual observation: the relocation statute technically did not even apply here, because Gomez (the parent seeking the move) was the non-custodial parent already living in Nevada, and the move was back to Nevada rather than away from it. But because no one raised this point and the trial court treated the statute as a guide, the appeals court reviewed the relocation analysis as instructive and found the trial court's findings were supported by the evidence. Finally, the court declined to address Likua's request for community funds to pay attorney fees, because the orders that actually denied or deferred those fees were not the ones she listed in her notice of appeal. The court also declined to address her claim of judicial bias, finding it moot because the case was being affirmed rather than sent back, and noting that even on the merits the bias claim would fail.

Timothy and Samantha Sheets share the same last name but were never married. They are the parents of a daughter, P.S., born in September 2022. Their relationship ended about a year after the child's birth, though Samantha continued living with P.S. in a house Timothy rented. The couple briefly reconciled in early 2024 and discussed moving away from Las Vegas, possibly to Montana, where Samantha had friends and family. In May 2024, after returning from a trip to Montana, the two had an altercation that led Samantha to call law enforcement. Timothy then filed a custody complaint seeking joint legal custody and primary physical custody, claiming Samantha had "abducted" the child. Samantha responded with her own request, asking for primary physical custody so she could relocate with P.S. to Billings, Montana. She gave several reasons: her extended family lived there, she would have free childcare, she had received a better job offer, and the area had cleaner air and water and a more rural lifestyle. Timothy opposed the move, arguing it would damage his relationship with the child and her relationship with her three half-siblings (his children from prior relationships, who lived in Las Vegas), and that Samantha was acting in bad faith to limit his contact and gain advantages in court. The district court first issued a temporary order giving Samantha primary physical custody, with arrangements built around Timothy's work schedule, which required him to work out of state—including in North Dakota—for two weeks each month. After a full evidentiary hearing with numerous witnesses, the court issued a detailed written order granting Samantha primary physical custody and permission to relocate to Billings. It awarded Timothy one week of parenting time per month, with a default schedule that the parties could adjust by mutual agreement to fit Timothy's work schedule. Timothy appealed. The Court of Appeals explained that a trial court has broad discretion in custody matters, and an appeals court will not disturb those decisions unless there was a clear abuse of discretion—meaning the decision was not supported by substantial evidence or was clearly erroneous. The appeals court emphasized that it does not re-weigh the evidence or re-judge the credibility of witnesses; that is the trial judge's job because the judge actually saw and heard the witnesses. Applying that standard, the court found that substantial evidence supported the district court's conclusion that Samantha had a "sensible, good faith reason for the move." Samantha and her prospective employer, Dr. Kayla Erickson, both testified about the legitimacy of the job offer, and Samantha testified about wanting to live near family, obtain free childcare and housing from her mother, and pursue better career opportunities. The court also reviewed the relocation factors from a Nevada Supreme Court case called Schwartz and the statutory "best interest of the child" factors, concluding that the trial court's findings—including that Samantha was more likely to support the child's relationship with her father and better suited to meet the child's needs—were supported by the evidence. While the court acknowledged that the child's relationship with her half-siblings favored Timothy, the trial court found that factor was "mitigated" by uncertainty over whether one half-sibling's mother (Jodi) would herself relocate closer to Montana. On the parenting time schedule, the appeals court noted that Timothy himself had not presented evidence clarifying how his work schedule was set or how far in advance he knew it, and he offered no concrete alternative schedule the trial court could have adopted. Because the order allowed the parties to adjust the default schedule by mutual agreement, the court found the schedule was supported by substantial evidence. The Court of Appeals affirmed the district court's order in full.

Ronald and Rachel Smith were married in 2015 and have one child, O.S., born in 2013. In April 2024, Rachel filed for divorce and child custody, and she obtained a temporary protection order (TPO) - a court order limiting contact - based on allegations that Ronald was behaving in a hostile and irrational way. The couple's main income came from running an Airbnb out of their home, and they had fallen behind on payments and risked losing the home to foreclosure. Rachel asked for, and the court granted, permission to list the marital residence for sale. For several months Ronald did not respond to the case. Because of this, Rachel asked for a "prove-up hearing" - a hearing where a party can prove their case when the other side has not participated. Shortly before that hearing, Ronald began filing his own documents as a self-represented party. He asked the court to let the parties share custody, to stop the sale of the home, and to allow discovery into more than $100,000 in claimed community debt. At a September 2024 hearing, Ronald objected to a $444,000 offer on the home, saying it was unfair, and the court continued the matter for an evidentiary hearing - a hearing where witnesses testify and evidence is presented. At the evidentiary hearing, both parties appeared and Ronald represented himself. Rachel's witnesses - a real estate agent and the home loan holder - testified. The real estate agent testified that Ronald posted information online that hindered the sale, causing the parties to lose the $444,000 offer, leaving a next-best offer of $300,000, and that Ronald made bad repairs that created code-compliance problems. The loan holder testified that Rachel was willing to sell but Ronald refused to sign off. Rachel also testified about her efforts to sell the home, the assets and debts, and her role as the child's primary caregiver. Ronald did not testify, but he gave opening and closing statements and cross-examined the witnesses. The court then issued the divorce decree. It found that Ronald had incurred $6,000 in community waste by staying in expensive Las Vegas hotel rooms during the divorce, that the parties lost the higher offer on the home, and that Ronald claimed over $100,000 in community debt but provided no evidence of it. Finding compelling reasons for an unequal split, the court awarded Ronald 50 percent of the home-sale proceeds and gave Rachel the remaining personal property (worth about $40,000, including vehicles and equipment) plus a vacant plot of land, with Ronald receiving $5,000 more from the sale proceeds as an equalization payment for that land. The court awarded Rachel sole legal and primary physical custody, with Ronald receiving supervised parenting time, finding this was in the child's best interest. On appeal, Ronald argued he was denied a fair process because he claimed he never received Rachel's financial disclosure form or witness list, and because the hearing went forward without full disclosures. The appeals court rejected these arguments. The record showed Rachel mailed her financial disclosure form and her pretrial memorandum (which listed her witnesses and documents) to the California address Ronald himself had listed in his filings. Under the rules, service is complete when documents are mailed to a party's last known address, so the court found Ronald had adequate notice. The court also said that if the address was wrong, it was Ronald's responsibility to keep the court informed of his current address. A key problem for Ronald's appeal was that he did not provide the appeals court with a transcript of the evidentiary hearing. Without it, the court could not tell whether Ronald raised these issues below, what evidence he claimed he was prevented from offering, or how any such evidence might have changed the result. When necessary parts of the record are missing, the appeals court presumes the missing materials support the lower court's decision. The court also noted it does not re-weigh witness credibility or evidence on appeal. For these reasons, it affirmed the divorce decree.

Sarina Lewis and John Lewis previously divorced under a stipulated (agreed-upon) decree that included child custody terms. Sarina later asked the trial court to change the custody arrangement, and the trial judge denied that request. Sarina, representing herself without an attorney, appealed that denial to the Nevada Supreme Court. When someone appeals, the Supreme Court requires certain paperwork on a schedule - including a form telling the court whether transcripts of the lower-court proceedings will be ordered, a "docketing statement" describing the case, and an opening brief explaining why the lower court got it wrong. The Supreme Court told Sarina on July 22, 2025, what was due and when. When she missed those deadlines, the court gave her a second chance on August 29, 2025, with a warning that missing the new deadlines could end her appeal. She did not file the transcript request form, the docketing statement, or the opening brief, and she did not otherwise contact the court. Concluding that she had abandoned the appeal, the Supreme Court dismissed it. The dismissal does not address the merits of the underlying custody dispute; it ends this particular appeal because the procedural requirements were not met.

This case is about whether grandparents can be granted court-ordered visitation with their grandchildren over the objection of the children's father. Marcos Alcala and his then-wife Esmeralda share three minor children. In 2019, the children were taken into the custody of Child Protective Services (CPS) after Marcos was arrested for several criminal offenses and after substance abuse issues involving both parents. The children were placed with their maternal grandparents, Cristina and Jacob Bello. Marcos and Esmeralda later divorced, and Esmeralda gave up her parental rights. Marcos eventually completed his case plan, and in 2023 the children were returned to him. After the children went back to Marcos, the Bellos asked a court for the right to visit the children. They said the children had lived with them, that they had formed close relationships, and that Marcos was denying or unreasonably restricting their visits. Marcos opposed, saying the Bellos had previously tried to come between him and his children and that there were possible safety risks. His main worry was that the Bellos would let Esmeralda and her new husband have contact with the children. The district court held a hearing where the Bellos, Marcos, and several other witnesses testified. Under Nevada law, because Marcos is a fit parent and had denied visitation, the law starts with a presumption that giving grandparents visitation is not in the children's best interests. The grandparents could overcome that presumption only by showing, with "clear and convincing evidence" (a demanding standard of proof, higher than the ordinary "more likely than not"), that visitation was in the children's best interests. After weighing the evidence and a list of factors set out in the statute, the district court found that the Bellos had met that high standard. It found the children had lived with the Bellos, had bonded with them, and that Marcos had denied or unreasonably restricted visits—at one point offering only a single two-hour supervised library visit and otherwise denying all visits. The court awarded the Bellos visitation one weekend a month (the third Friday at 5:00 p.m. until noon on Sunday). To address Marcos's main concern, the court ordered the Bellos not to allow Esmeralda or her husband to have contact with the children during those visits. On appeal, the Court of Appeals affirmed. It concluded that the district court correctly applied the legal presumption and the clear-and-convincing-evidence burden, and that the court's factual findings were supported by the evidence. The appeals court explained that it does not re-weigh conflicting evidence or second-guess a trial court's judgments about which witnesses to believe. It also rejected Marcos's claim that his due process rights were violated, noting that he received advance notice of the request and hearing, appeared, questioned witnesses, and presented his own evidence.

Paulina and Randy Sotelo married in October 1997 and had three children, two of whom were still minors when the case went to trial. Both spouses worked during the marriage, but in 2018 Paulina developed chronic diastolic heart failure that prevented her from working, and she began receiving permanent disability benefits. In 2005, the couple bought a house for $350,000 using community funds (money belonging to the marriage). However, the purchase documents — the grant, bargain, and sale deed and the deed of trust — named only Paulina as the owner and described the house as her "sole and separate property." Randy also signed a quitclaim deed giving up his interest in the house to Paulina at the time of purchase. Despite this paperwork, both parties agreed that community funds were used to pay the mortgage during the marriage. Randy filed for divorce in February 2023. Several issues were contested: who would have custody of the children, whether the house belonged solely to Paulina or to the marriage, and how alimony (financial support paid by one ex-spouse to the other) should be structured. The district court gave Randy primary physical custody of the younger child, G.S., and gave the parties joint physical custody of E.S. On the house, the district court ruled it was community property, ordered it sold to pay off the couple's community debt, and ordered the remaining money split equally. The court also awarded Paulina alimony of $750 per month — at first for 11 years, later extended to permanent (indefinite) alimony — and refused to give her the alimony as a single lump-sum payment. The alimony payments were also set to begin only after the home was sold. Paulina appealed. On the question of who owned the house, the Court of Appeals agreed with the district court. Although the deeds and the quitclaim deed might ordinarily have suggested the home was a gift to Paulina (and thus her separate property), Paulina never actually submitted those documents as evidence at trial. More importantly, she had told the court in her pretrial papers that the house was put in her name because Randy was "financially unstable" at the time — meaning the transfer was done for financial reasons, not as a gift. She also agreed at trial, when the judge asked, that the home was a community asset. Because property bought during a marriage is presumed to belong to the marriage unless proven otherwise by strong evidence, and Paulina did not overcome that presumption, the court upheld the community-property ruling. However, the Court of Appeals found problems with how the district court handled the alimony and the sale of the home. The district court had refused to consider the value of the home — and therefore how much equity (the home's value minus what was owed) the couple had — because it was dissatisfied that the value estimate came from the Zillow website rather than a formal appraisal. But both parties had provided Zillow-based figures, neither objected, and they effectively agreed those figures were reliable. The evidence indicated the home had roughly $237,000 in equity against only about $27,000 in community debt. Paulina had testified that on her monthly disability income of $1,487 she could not afford to rent a house or apartment in Las Vegas even with child support and periodic alimony, but that she could afford the existing monthly mortgage of $1,268.47 and keep the family home for herself and the children. She had asked the court for a lump-sum alimony award that would offset Randy's share of the home's equity, in exchange for giving up any claim to Randy's retirement benefits. The Court of Appeals concluded that the district court did not give adequate consideration to her request to keep the home, did not properly weigh the hardship of losing it when she might be left without reasonable housing, and did not properly analyze whether lump-sum alimony would be more appropriate. The court sent these issues back to the district court to reconsider.

This is a short procedural order ending an appeal before the Nevada Supreme Court ever reached the merits. Jamie Irene Randolph filed an appeal from a divorce decree issued by a Clark County district judge. To move an appeal forward, the person who filed it must submit an "opening brief" - a written document explaining what the lower court did wrong and why the appellate court should change the result. Because Ms. Randolph did not have a lawyer, the Supreme Court told her she could either file a formal brief that follows specific rules of appellate procedure or use a simpler "Informal Brief Form for Pro Se Parties" that the court provides for people representing themselves. On May 2, 2025, the court sent her a notice setting a September 2, 2025 deadline to file one of those two documents and warning that missing the deadline could result in dismissal. When that deadline passed with no filing, the court issued a second order on September 10, 2025, giving her another seven days and again warning that the appeal could be dismissed. When Ms. Randolph still did not file anything or otherwise contact the court, the Supreme Court concluded she had abandoned her appeal and dismissed it. The order does not address the underlying divorce decree or any custody issues on the merits.

This is a one-page clerk's order ending an appeal in a child custody case. The person who filed the appeal, Aboyepe Adekile, asked the Nevada Supreme Court to dismiss the appeal voluntarily - meaning he chose not to continue pursuing it. The court granted that request and closed the case. The order does not decide any custody issue, does not address the merits of the underlying dispute, and does not explain why the appellant chose to withdraw. It simply ends the appeal.

This is a child-custody dispute in which the father, Troy Daniel Heath, asked the family court to end the requirement that his visits with the child be supervised. The family court said no, ordered the supervised visits to continue, and directed him to resume a program called the Options Patch Program. He then tried to appeal that decision to the Nevada Supreme Court. The Supreme Court did not decide whether the family court was right or wrong about the visitation. Instead, it concluded that it has no power to hear this appeal at this stage. In Nevada, a person can only appeal certain kinds of decisions - those that a statute or court rule specifically allows to be appealed. The court explained that while a final decision denying a request to change custody usually can be appealed, this order dealt only with temporary supervised visitation, not a final custody decision. Because temporary custody orders can be revisited and changed by the lower court, they are not the kind of final ruling the Supreme Court can review. The court therefore dismissed the appeal for lack of jurisdiction.

This is a child custody dispute between Angel-Khalil Jones and Unique Fashion Williams. In June 2024, a family court judge entered an order giving Jones only limited, supervised visits with the child, at least until a related dependency case concluded and Jones filed a motion to change custody. Jones asked the judge to reconsider; that request was denied in October 2024. Jones did not appeal within the 30-day window the rules require. In April 2025, Jones filed a different kind of motion - a motion to "set aside" the June 2024 order. The district court denied that motion in May 2025, calling it untimely and successive (meaning it repeated arguments already raised). Jones then appealed in May 2025. The Nevada Supreme Court explains that, to the extent Jones was trying to appeal the original June 2024 custody order, his appeal came far too late. Under the appellate rules, an appeal must be filed within 30 days after notice of entry of the order, and missing that deadline means the Supreme Court has no power to hear the appeal at all. To the extent Jones was appealing the May 2025 order denying his motion to set aside, the court did not decide whether that order was even appealable. Instead, the court found the issue moot - meaning circumstances have changed so much that no ruling from the Supreme Court could provide meaningful relief. By the time the appeal was being considered, both parents had filed new motions to modify custody, the mother was seeking to relocate, and a multi-day evidentiary hearing was already underway. The district court had entered a new temporary custody order in March 2025 (and additional temporary orders since), so the parties were no longer operating under the June 2024 schedule at all. The trial court is expected to enter a final custody order after the evidentiary hearing concludes, and any party unhappy with that final order can appeal it then. The court also addressed a housekeeping issue. Two attorneys, Jennifer Setters and Yadira Santana, filed a notice saying they did not represent the respondent. They cited the wrong subsection of NRAP 46 (the criminal-case provision) rather than the civil-case provision, and their notice was filed late. Because the respondent had already filed her own response without a lawyer, the court accepted the late notice and removed the attorneys from the case. Because the appeal was dismissed, Jones's various emergency motions - to halt the district court proceedings, to restore his parenting time during the appeal, to unseal certain records, to waive transcript costs, and to extend his briefing deadline - were all denied as moot.

Tiffanee and Thomas Bruchu divorced in August 2020 and share one child, W.B., born in January 2016. At first they shared joint legal and physical custody. At some point Thomas moved from southern Nevada to Utah. After an August 2023 hearing, the district court confirmed a stipulated change giving Tiffanee primary physical custody, and a May 2024 stipulation and order continued that arrangement: joint legal custody, with Tiffanee having primary physical custody subject to Thomas's parenting time. In March 2025, both parents filed competing motions. Tiffanee asked the court to order the return of W.B. from Utah, saying Thomas had not returned the child as the existing custody order required; the district court denied her motion. Thomas asked for sole legal and primary or sole physical custody. He alleged that while W.B. was with him he found explicit photos and videos the child had taken of herself on her phone while in Tiffanee's care, and that she had been exchanging explicit pictures with men. He said he had turned the phone over to Henderson's Special Victims Unit and that child-protection cases had been opened in both Nevada and Utah, and he asked to keep custody until the investigation was complete. After a hearing, on April 7, 2025, the district court entered an order that, "[o]n an [e]mergency basis, and temporarily, pending final briefing," allowed W.B. to remain in Utah with Thomas. A return hearing followed, and on June 6, 2025, the court entered another order letting W.B. stay in Utah with an out-of-state holiday parenting-time schedule. That June order did not discuss relocation or the factors courts use to decide a child's best interests. A full evidentiary hearing on Thomas's custody request was set for December 23, 2025. Tiffanee filed many motions to change or pause the custody order, which the district court denied without a hearing. She then brought this writ petition. A writ of mandamus is a court order directing a lower court to perform a legal duty or to correct an arbitrary or capricious use of its discretion. Because the district court's custody order was temporary rather than final, it could not be appealed in the ordinary way, and the Court of Appeals chose to consider the petition because it involved important legal questions affecting a minor child and the record was adequate. The Court of Appeals concluded that relief was warranted. The court acknowledged that when a judge makes a temporary custody order in an emergency with only limited information, it may not be practical to make all the findings normally required. It also acknowledged that custody decisions are owed deference and reviewed only for abuse of discretion. But the court explained that deference is not owed to legal error or to findings so conclusory they may mask legal error. Here, the challenged order moved primary physical custody from Tiffanee to Thomas and effectively required the child to relocate to Utah, yet the district court made no explicit finding of a change in circumstances, did not address relocation factors or the child's best interests, and did not find that the child would be unsafe if Tiffanee kept primary physical custody. The June 6 order also contained no finding that emergency circumstances continued or that investigations were ongoing. The court also found a problem with timing. A Nevada court rule, SCR 251, requires district courts to resolve custody motions within six months of when an opposition is filed, unless the court explains why more time is needed. The dispute began in March or April, the challenged order was filed June 6, but the evidentiary hearing was set for December 23 - more than six months later - with no findings in the record justifying the delay. The Court of Appeals directed the district court to vacate the April 7 and June 6 orders, reinstate the May 2024 stipulated custody order, and either justify the December 23 hearing date as SCR 251 requires or set a new compliant date. The court noted that nothing in its order prevents the district court from entering an emergency custody order under exigent circumstances or holding an abbreviated, expedited hearing for temporary physical custody. One judge dissented, writing that the record - missing the full briefing, evidence, and hearing transcripts from the district court - did not show that the district court abused its discretion, and that the missing materials should be presumed to support the district court's decision.

Giana Curreri and Marcus Mayhall are the parents of a child born in 2015. They were never married. Beginning in 2017, they filed competing requests for custody and eventually agreed to share joint legal and physical custody. Over several years, Curreri repeatedly alleged that Mayhall was sexually abusing their son, prompting investigations by Washoe County Child Protective Services (CPS) and law enforcement. According to the opinion, those investigations concluded the allegations were unsubstantiated. The district court became concerned that Curreri was subjecting the child to unnecessary physical examinations and forensic interviews. A parenting evaluation indicated Curreri may suffer from paranoid personality disorder that affected her ability to co-parent and caused harm to the child. The custody arrangement shifted several times, including periods where Mayhall had temporary primary physical custody and Curreri had parenting time or supervised visitation. In May 2023, Mayhall filed an emergency motion arguing Curreri was coaching the child to make false abuse allegations. Curreri filed a counterpetition again alleging abuse, sex trafficking, and fraud by Mayhall's counsel. After an emergency hearing and later an evidentiary hearing in September 2023, the district court awarded Mayhall sole legal custody and primary physical custody, gave Curreri weekly supervised parenting time, and ordered the child to remain in counseling and Curreri to seek treatment. In November 2024, Curreri filed a new combined ("omnibus") motion asking the court to change custody again, to take judicial notice of facts in the record, and, alternatively, to vacate all prior orders under NRCP 60(b) (a rule that allows a court to set aside earlier orders in certain circumstances). She argued the earlier investigations were inadequate, that the court had ignored evidence proving abuse, and that the judge and Mayhall's attorney had engaged in misconduct dating back to 2017. The court gave her a chance to file an amended motion identifying any change in circumstances occurring after the 2023 order. Her follow-up declaration and exhibits did not identify any such new change; instead they reviewed the case history and made more detailed misconduct allegations. The district court denied the motion to change custody without holding an evidentiary hearing, finding Curreri had not alleged any change in circumstances after the 2023 order. It denied the judicial-notice request because it was unsure what facts Curreri wanted noticed. It denied the NRCP 60(b) request because it had already reviewed and rejected the same misconduct allegations in prior orders. The Court of Appeals agreed with the district court. It held the district court did not abuse its discretion in denying the custody-modification motion without a hearing because Curreri had not pointed to anything that changed after the 2023 order, and her abuse allegations had already been litigated. It affirmed the denial of NRCP 60(b) relief because the same arguments had been raised and rejected before. It rejected her claim that the judge was biased, finding she did not develop a coherent argument. It affirmed the denial of the judicial-notice request because she did not identify the facts on appeal. Finally, it dismissed, as untimely, the part of her appeal that tried to challenge the 2023 custody order and the 2017-2019 orders.

Two parents, Dexter Farlough and Alana Cooper, share two children. In 2016, an Arizona court had given Farlough sole decision-making authority over the children and had identified Arizona as the children's "home state" at that time. By the time this case began, however, the situation had changed: Cooper filed a custody complaint in Nevada in January 2024, stating that she and the children lived in Nevada and asking for joint legal and physical custody. Farlough, in his own filings, also stated that he now lived in Nevada and that he and the children had moved to Nevada on June 3, 2023 - more than six months before Cooper filed her complaint. During several hearings, both parents told the court they all lived in Nevada. The court observed that no one seemed to want Arizona to keep handling the case since everyone had moved away. The parents reached agreements on most issues, including sharing joint physical custody, financial matters, and a holiday and vacation schedule. The one sticking point was legal custody - the authority to make major decisions about the children. The judge proposed that the parents share joint legal custody, but that Farlough would have the final say on medical and educational matters (one child has serious medical and educational needs, and Farlough felt he knew more about them). Cooper agreed, and Farlough said the parents had "a full agreement." The court then put all of this into a written custody decree. Farlough appealed. He raised four arguments. First, he said Arizona, not Nevada, should have decided the case. The Court of Appeals disagreed, pointing out that under the relevant rules, Nevada has authority when it is the children's "home state" (where they have lived for at least six consecutive months) and when no one still lives in the other state - and Farlough's own filings established both facts. Second, Farlough argued the court was wrong to treat the joint legal custody arrangement as something the parties had agreed to. The court rejected this, noting that the record showed Cooper agreed to the proposal and Farlough himself said they had "a full agreement." Third, Farlough claimed he was not properly notified of hearings or of Cooper's motion. The court found that he had been served through the court's electronic filing system and that Cooper's motion showed it had been mailed to him - and that he actually appeared at the key hearings where the agreements were made. Fourth, Farlough argued the judge was biased against him because of his gender. The court found no support for this, explaining that a judge's rulings made during the case generally cannot prove bias unless they show a deep-seated hostility that would make fair judgment impossible. Because none of Farlough's arguments succeeded, the Court of Appeals affirmed the custody decree.

This is a child custody dispute between two divorced parents. Since December 2020, by stipulation, the mother (Melanie Blackwood) has had sole legal and physical custody of the parties' two youngest children in Oklahoma, with no child support flowing in either direction. In 2023, she asked for child support, and the father (Mark L. Blackwood) asked the court to begin a reunification process with the children. The district court held an evidentiary hearing in late 2024, but did not issue its written ruling until May 21, 2025. That ruling gave the parents joint legal custody, gave the mother primary physical custody, ordered reunification therapy with a future goal of in-person visitation in Nevada, and granted the mother's request for child support. The order also contemplated mediation after six months of therapy to negotiate a permanent out-of-state visitation arrangement. Between the late-2024 hearing and the May 21 written order, the father filed two emergency motions claiming new incidents had occurred. The mother filed a countermotion seeking sole custody. On April 21, 2025, the district court issued a separate order finding that the father's emergency motion warranted a new evidentiary hearing, set for July 17, 2025. Because the mother then filed a notice of appeal from the May 21 order, the 2025 custody proceedings stalled over jurisdictional concerns - once a case is on appeal, the trial court generally cannot continue to act on the same issues without permission. The father then asked the Nevada Supreme Court to send the case back to the district court so that court could address the new emergency issues. He pointed to a July 22, 2025, district court order certifying that remand was appropriate to consider the emergency custody motions further. The mother opposed, arguing the May 21 order had resolved everything and that the emergency motions raised nothing new. The Supreme Court observed that it was "unclear" whether the May 21 order was actually a final, appealable order, given that another custody motion was already pending and the order left visitation to future proceedings. Rather than resolve that jurisdictional question, the court accepted that further proceedings in the district court were necessary because of recent events affecting the children. It granted the remand, dismissed the appeal, and directed the district court to expeditiously enter a new written order resolving custody (legal and physical) and support. Any future appeal must be taken by filing a new notice of appeal from that new order.

Mark Blackwood asked the Nevada Supreme Court to issue a writ of mandamus - a court order forcing a lower court to take an action it is legally required to take - directing the district court to rule promptly on emergency motions about his children's custody. He argued that because his ex-spouse, Melanie Blackwood, had filed a separate appeal, the family-court case had stalled, putting the children at risk. The Supreme Court declined to step in. It explained that this kind of extraordinary order is available only when a person has no other adequate way to get relief. Here, the court pointed out that Mark already had an alternative path: he could file an emergency motion directly in the pending appeal under the appellate rules, and he had in fact already filed a non-emergency motion for remand in that appeal. The court also reminded the parties that even when an appeal is pending, the district court keeps the power to issue emergency orders if needed - so the family court is not actually frozen on urgent child-safety questions. To the extent Mark also asked the Supreme Court itself to temporarily place the children with him, the court declined, saying that kind of decision should be made by the district court first. Finally, the court flagged a procedural problem: although Mark sought immediate review, his filing did not include citations to the multi-volume appendix to back up his factual claims, which slowed the court's review. The court advised counsel to provide such citations in any future emergency petitions.

Leslie and Josue Ortiz married in 2016 and Leslie filed for divorce in 2023. A central dispute in the divorce was who owned a condominium on Cardiff Lane that Josue had purchased in December 2018 for $110,000 with a $10,000 down payment. When the condo was purchased, Leslie signed a deed (a "grant, bargain, sale deed") that transferred her interest in the property to Josue, leaving it in his name alone. At trial, Leslie testified that she did not realize she had signed a deed, thought the document was for loan purposes, received no money for signing, and did not intend to give the property to Josue. Josue testified differently: he said the couple had discussed the purchase and agreed he would buy the property in his own name as his own property, and that the couple generally kept their finances, assets, and debts separate. He acknowledged he gave Leslie no money in exchange for the deed and that the couple had no written prenuptial or postnuptial agreement other than the deed itself. The district court decided that the Cardiff property was Josue's separate property. The court found Leslie's testimony not credible on the question of whether she knew the property was being bought as Josue's separate property, and found Josue's testimony credible. The court treated Leslie's signing of the deed as a gift of the property to Josue. The court also ruled that Leslie's cleaning business was her own separate property and ordered each spouse to keep their own bank accounts, debts, and vehicles. The Court of Appeals agreed with part of the district court's decision and disagreed with another part. On the question of whether Leslie had given Josue her interest in the property by signing the deed, the appellate court upheld the district court. Under Nevada law, when one spouse transfers title of property to the other spouse, the law presumes it was a gift, and the spouse who gave it up must prove with strong evidence ("clear and convincing evidence") that it was not. Because the two spouses gave conflicting accounts and the district court chose to believe Josue, and because appellate courts do not re-decide who is telling the truth, the Court of Appeals affirmed that Leslie gifted the title and the $10,000 down payment to Josue. But the appellate court found a gap in the lower court's reasoning. Even though Leslie gave Josue the property, Josue continued to pay the mortgage during the marriage. In Nevada, the wages a spouse earns during marriage generally belong to the "community" - that is, to both spouses jointly. There was no evidence Josue used any separate (non-community) money to pay the mortgage, so the court inferred he paid it with his earnings, which were community funds. When community money is used to pay down a mortgage and improve a property, the community can gain a share of the increased value. Josue also refinanced the property in 2023, pulled out money for home improvements, and the property's value rose to about $220,000. The district court never made findings about whether the use of community funds to pay the mortgage and make improvements gave the community an interest in the increased value of the condo. Because of this missing analysis, the Court of Appeals concluded the decision to award the property entirely to Josue as separate property was not supported by adequate evidence and findings. It sent the case back to the district court to perform a specific calculation (a "Malmquist analysis") to determine how much of the property's value is separate and how much belongs to the community, and to divide the community's share between the parties.