Nevada family-law case summaries

This is a short procedural order, not a ruling on the merits of the underlying child custody dispute. When a person files an appeal in Nevada, court rules require them to serve (formally deliver) the notice of appeal on the other parties and to file paperwork with the court showing that service occurred. When Mr. Agee filed his appeal on June 13, 2025, that proof-of-service paperwork was missing. The Supreme Court Clerk sent him a notice the same day giving him 14 days to provide it and warning that failing to do so could result in dismissal. He did not respond. On July 9, 2025, the court issued a follow-up order again giving him 14 days and again warning that noncompliance would result in dismissal. He still did not comply. Because the appellant did not file the required proof of service after two warnings, the court dismissed the appeal. The order does not address the substance of the custody dispute below.

Nick Bryant and Megan Sorget were never married but share one child, S.B., born in 2013. From 2015 to 2021 they shared custody equally under an agreed court order. In December 2020, Sorget asked the court for permission to move to Michigan with S.B. to live with her husband; the court said no. Bryant was then given primary physical custody, and Sorget received summer and holiday time plus the option of ten additional days per month in Las Vegas with advance notice. Sorget moved to Michigan anyway (without S.B.), divorced her husband in February 2024, and moved back to Nevada in March 2024. Once back in Nevada, the parents could not agree on a new schedule. Bryant asked the court to adjust the timeshare while keeping him as the primary custodian; Sorget asked to return to the equal, joint custody schedule the parties had used before she left. After a temporary week-on/week-off schedule and an evidentiary hearing - a trial-like proceeding where witnesses testify under oath - the district court sided with Sorget. It found that her return to Nevada was a "substantial change in circumstances" (the legal trigger required before a court can revisit custody) and that joint physical custody was in S.B.'s best interest, pointing to factors such as the level of conflict between the parents, their ability to cooperate, and the child's developmental and emotional needs. The court also recalculated child support: because Bryant earns about $7,498 per month and Sorget was not working, the standard formula would have set his obligation at $1,080 per month, but the court reduced it to $500 per month after considering Sorget's household income of roughly $10,000 per month (supplied by her ex-husband, with whom she had reconciled) and her responsibility for her other two children. On appeal, the Nevada Court of Appeals upheld everything. It explained that appellate courts do not second-guess a trial judge's weighing of the evidence or decisions about which witnesses to believe; they ask only whether the findings are supported by "substantial evidence" - evidence a reasonable person could accept. The court found the record supported the conclusion that Sorget's return to Nevada changed circumstances in ways affecting S.B.'s welfare (more frequent contact, more availability for daily routines) and that the best-interest findings were adequately supported. On child support, the court held that Sorget's credible testimony - that caring for S.B., her two other children (one with cerebral palsy and other special needs), and her fiancé's five children left her unable to work outside the home - gave the district court good cause not to attribute pretend income to her, and that the district court adequately explained why it lowered Bryant's payment below the guideline amount. Sorget's claim on appeal that she is no longer with her ex-husband, which apparently arose after the hearing, was not considered because it was never raised in the district court, though the court noted she may raise it there as a possible basis to modify support going forward.

This case involves a baby, A.R., who was removed from her parents in 2022 because of neglect and abuse. The Clark County Department of Family Services (DFS) initially placed her with her paternal aunt, Mary. Over time, A.R. also began spending weekends with her maternal grandmother, Ericka. Both relatives loved A.R., wanted to adopt her, and were considered fit caregivers. After the parents' rights were terminated by the court, the district court had to decide where A.R. should live permanently. Both the aunt and the grandmother were good options, and the district court found them "equally situated" in most respects. To break the tie, the court considered DFS's recommendation. DFS preferred the aunt's home because A.R. had developed a close, sibling-like bond with her cousin (the aunt's child), and DFS believed keeping that bond intact was best for A.R. The court placed A.R. with the aunt for adoption, while preserving the grandmother's role through a Post Adoptive Contact Agreement giving her alternating weekend visits and two weeks of summer vacation each year. The grandmother asked the Nevada Supreme Court to step in through a writ of mandamus - a court order directing a lower court to perform a duty required by law. She argued the district court placed too much weight on DFS's recommendation, did not make sufficient findings, did not hear enough evidence, and improperly favored a "nuclear family" structure. The Supreme Court rejected those arguments and denied the petition. It explained that, after parental rights are terminated, a different statute (NRS 128.110) governs placement, and that statute gives the agency holding the child's custody discretion in deciding placement. The district court is not bound by the agency's preference, but it must consider it as part of figuring out what is in the child's best interest, which always remains the paramount concern. Here, the district court did exactly that: it acknowledged it could override DFS, but found DFS's reasoning - protecting A.R.'s bond with her cousin - persuasive. The Supreme Court also concluded that the district court's findings were sufficient and that its decision was not based on a generic preference for "traditional" families but on the specific facts of A.R.'s relationships. Some of the grandmother's other arguments were treated as waived because she did not raise them in the district court.

Janelle Duran and Jimmie De Armas were never married but share two children, born in 2010 and 2014. In March 2023, Duran filed a court case asking for sole legal and primary physical custody. De Armas responded asking for joint custody and later for primary physical custody. Before the trial, Duran's attorney withdrew from the case (was allowed to stop representing her) on August 1, 2023. Trial was set for August 29. Duran did not do much during that nearly one-month window except file a last-minute request on August 24 to delay the trial, which the court denied the next day. Because Duran had not filed a required pre-trial memorandum, had not submitted proposed exhibits, and had not taken part in the discovery process (the pre-trial exchange of information), the court ruled she could not present documents or exhibits at trial. The court did, however, tell her she could still testify. Duran chose not to testify and instead "rested on her pleadings" (relied only on the documents already filed, presenting no live testimony). At trial, De Armas was the only witness. He testified about Duran withholding the children, not cooperating with him, changing the children's schools without telling him, frequently calling the police on him, and other concerns. The district court then issued a custody decree giving the parents joint legal custody but awarding De Armas primary physical custody, with Duran having weekend parenting time. The court found that several of the legal "best interest" factors favored De Armas. On child support, the court decided Duran was capable of working but was not, and "imputed" income to her — meaning it treated her as if she earned a certain amount ($18.00 per hour, or $3,120 per month) for the purpose of calculating support. Her child support obligation was set at $668 per month. The court also ordered that the modeling earnings of the younger child be placed in a blocked bank account for that child's benefit, because it found Duran had sole access to those earnings. While Duran's appeal was pending, De Armas asked to send the case back to the trial court so it could consider his request to change custody. The appeals court allowed a limited remand. On remand, after an evidentiary hearing where both parents testified, the district court gave De Armas sole legal custody (the right to make major decisions for the children), kept physical custody as it was, and ordered Duran to attend individual therapy — one appointment per month for six months — finding the therapy would help her and, in turn, the children. Duran appealed all of this. The Court of Appeals affirmed every part. The court explained that it reviews custody and support decisions for "abuse of discretion," a deferential standard meaning it will not overturn the trial court unless the decision lacks support in the evidence or is clearly wrong. On the continuance and the exclusion of evidence, the court noted Duran never explained what evidence she would have offered or how it would have changed the result, and she declined the chance to testify. On the child interviews, the court explained that judges have discretion whether to interview children, and Duran did not actually challenge the trial court's reasons. On child support, the court found substantial evidence supported imputing income, and it emphasized that appellate courts do not re-weigh evidence or re-judge witness credibility. On the legal-custody modification, the court found the trial court's findings adequately showed a substantial change in circumstances and that the change served the children's best interest. Importantly, Duran did not provide a transcript of the evidentiary hearing, so the court presumed the missing transcript supported the trial court's findings. On the therapy order, the court found the trial court made sufficient findings tied to the children's best interest.

This case arose from a divorce in Clark County. The district court issued a temporary order addressing child custody, relocation, financial support, and supervised visitation while the divorce case continued toward a full evidentiary hearing. The husband appealed that temporary order to the Nevada Supreme Court and asked the court to put the order on hold while the appeal was pending. The Supreme Court did not reach the merits. Instead, it dismissed the appeal because it concluded it lacked authority to hear it. Under Nevada law, appeals are allowed only when a statute or court rule specifically permits them. Temporary custody and support orders are generally not the kind of orders that can be appealed; only final orders resolving custody can. The court explained that even though the appellant argued the temporary order had immediate, life-altering effects, the district court could still alter or remedy those conditions after holding the evidentiary hearing - so the order was not final. The court also declined to convert the appeal into a writ proceeding (a separate procedural mechanism for asking a higher court to intervene). It noted, however, that the dismissal does not bar the appellant from filing a separate writ petition. Because the appeal was dismissed, the emergency motion for stay was denied as moot.

Joseph Shellmire and Kyonda Hall, who were never married, have two children together: a son born in 2010 (J.S. Jr.) and a son born in 2016 (J.S.). In March 2022, Shellmire went to court asking for joint legal and physical custody, claiming that starting in 2020 Hall had blocked him from seeing the children. Hall responded by asking for sole legal and physical custody and denied that she had kept the children from him. After a hearing in April 2024, the two parents told very different stories. Shellmire said he had been an involved father, especially to the older boy, and that Hall had cut off his access to the children. During cross-examination, however, he admitted that he had actually continued to see the children at Hall's house because he and Hall kept up a sexual relationship until 2022, and he said that "at the time, that was the only way I could see my kids." Hall testified that she never restricted Shellmire's time with the children, that he only wanted them when convenient, and that she had been the parent primarily responsible for their care. The district court found Hall more believable than Shellmire. It concluded that Hall had not prevented Shellmire from being an active parent and that Shellmire wanted to be the "fun dad" without showing urgency about parenting. The court gave the parents joint legal custody but gave Hall primary physical custody. Because the two children had different relationships with Shellmire, the court set up different schedules: Shellmire got parenting time with the older son every other weekend, but for the younger son he could only see the child during reunification therapy. The court also set child support for the younger child and ordered Shellmire to pay $43,000 in constructive child support arrears (back support owed for a period before a support order existed). On appeal, the Court of Appeals reached three different results on the different parts of the order. First, on the overall custody award, the court affirmed. Shellmire essentially asked the appellate court to decide whether his lack of contact was Hall's fault or his own choice. But an appeals court does not re-weigh evidence or re-judge which witness was more believable; those calls belong to the trial judge who heard the testimony. Because both sides presented evidence a reasonable person could accept, and the trial court weighed it and analyzed the best-interest factors, the appellate court found no abuse of discretion. Second, on the parenting time with the younger child, the court reversed and sent the issue back. Even though the trial court called its order "primary" custody, the appeals court concluded that limiting Shellmire to seeing the child only during therapy effectively gave Hall sole physical custody. Under a recent decision, a court that severely restricts or eliminates parenting time must make specific findings explaining why, and the trial court had not done so. The appeals court ordered the trial court either to provide parenting time consistent with primary custody or to make the findings needed to justify the restrictions. Third, on child support, the court partly declined to consider an argument and partly affirmed. Shellmire's claim that the case should have been combined with a California support case was treated as waived because he never raised it in the trial court. On the $43,000 in back support, the court rejected Shellmire's statutory argument and upheld the award. The portion of the appeal about attorney fees was dismissed because a separate appeal challenging the fee award had already been dismissed.

This case never reached the merits. Samantha Fagan tried to appeal a district court order that addressed child support and also sanctioned her for contempt of court. Before considering whether the lower court got anything right or wrong, the Nevada Supreme Court had to decide whether it had the power to hear the appeal at all. The Nevada Supreme Court can only hear appeals that a statute or court rule specifically allows. Here, the court flagged a problem: the underlying custody dispute was still pending in the district court, meaning the order Fagan wanted to challenge was not a "final" decision. Nevada's appellate rules generally require finality before an appeal can be taken. Separately, the contempt-sanction portion of the order is not the kind of ruling that can be appealed on its own under existing Nevada Supreme Court precedent. The court asked Fagan to explain why the appeal should go forward. Fagan agreed that the order was not appealable under the rules the court identified and did not point to any other statute or rule authorizing an appeal. With no jurisdictional basis to proceed, the Supreme Court dismissed the appeal. Fagan may still pursue her arguments in the district court while the custody matter remains pending there; the dismissal addresses only the timing and form of appellate review, not the underlying merits.

Michael Jeffery and Merlaina Beckwith were never married but have three children together, born in 2013, 2014, and 2016. In September 2023, Jeffery, who then lived in Texas, filed a case in Nevada asking for sole legal and primary physical custody. Beckwith, who lived in Nevada with the children, asked for sole legal and sole physical custody, parenting time for Jeffery during spring and summer breaks, and back child support. Before the final hearing, the district court made temporary orders. It gave Beckwith temporary primary physical custody, named her the school-year parent, ordered her to take a drug test (which Jeffery was to pay for), and required the parents to communicate through an app called Our Family Wizard. Beckwith took the drug test, but Jeffery never paid for it, and the test was eventually destroyed. A major dispute arose over the 2024 spring break. Jeffery took the children to California during his parenting time and did not bring them back, causing them to miss school. According to the record, he had moved from Texas to Sacramento without telling Beckwith and intended to keep the children until she booked flights for them. The court repeatedly ordered him to return the children at his own expense. He initially said he could not afford tickets, then revealed he had also bought a plane ticket for his wife. By the time he returned the children, they had missed 21 days of school. At the final evidentiary hearing, the court heard from both parents and from Myrna Smith, the 70-year-old family friend the children lived with. Jeffery argued he should have primary custody because Beckwith interfered with his communication with the children, lacked stability, and could not keep the children safe. Beckwith admitted she had interfered with communication in the past but said she had improved, and admitted she "might not be great with stability," which she attributed to being a single parent with no financial support from Jeffery. The court did not let Jeffery's wife or brother testify, finding their testimony would repeat evidence the court had already heard. The district court found both parents "mostly credible" and both fit to parent, but found that both showed poor judgment and contributed to conflict. It found that the "abduction factor" favored Beckwith because Jeffery had withheld the eldest child for months in 2022 and had failed to return the children after spring break in 2024. The court concluded that if both parents lived in Clark County they would share joint custody, but because Jeffery lived in California, it was in the children's best interest for Beckwith to have primary physical custody. On appeal, the Court of Appeals kept the custody decision in place. It explained that it does not re-weigh evidence or re-judge witness credibility, and that the district court's decision was supported by adequate evidence and was not based solely on Beckwith's Nevada residency. The appeals court also upheld the district court's decisions to exclude Jeffery's two witnesses (their testimony would have been repetitive) and to allow Smith to testify (Jeffery did not object at the hearing and did not show the outcome would have changed). The appeals court did, however, send several money-related issues back to the district court. On child support, a recent Nevada Supreme Court decision (Martinez) held that a court cannot separately impose travel/transportation costs without figuring out how those costs affect the overall child support amount. Because the district court ordered the receiving parent to pay travel expenses in a separate part of the decree without folding that into the child support calculation, the appeals court reversed the child support award and sent it back. It emphasized it was not deciding whether the support amount should actually change. On child support arrears (past-due support), the court found that the record suggested there was already an existing child support obligation in place for the same time period, and under Nevada law, past-due child support that has already come due generally cannot be changed after the fact. Because the record did not show the amount of that pre-existing obligation, the appeals court vacated the arrears and sent that issue back for findings. If the amount turns out to be the same, the original order can be reinstated. On health insurance, the district court had ordered Jeffery to provide private health insurance even though it acknowledged it received no evidence on the issue, and the parties' filings suggested both expected the children to use Medicaid. The appeals court reversed that requirement and sent it back because it was not supported by the evidence. Finally, the court rejected Jeffery's claim that the judge was biased, explaining that unhappiness with a judge's rulings during a case is generally not enough to show bias, and that Jeffery had not shown the kind of deep-seated hostility that would make a fair decision impossible.

This case involves a parent, Jasmine Anderson-Alexander, who was unhappy with a child custody order entered by a family court judge in Clark County. Instead of (or in addition to) filing a regular appeal, she asked the Court of Appeals to step in immediately by issuing what is called an "extraordinary writ" - a special court order used only in limited circumstances. She asked for two possible types of writ. A writ of mandamus is a court order that forces a lower court or official to do something the law requires, or that reins in a decision made in an arbitrary or capricious way. A writ of prohibition is a court order that stops a lower court from acting when it has no legal authority (jurisdiction) to act. Both are considered emergency, out-of-the-ordinary remedies. The Court of Appeals explained that deciding whether to take up this kind of emergency writ petition is entirely within its own discretion, and that the person asking for the writ carries the burden of showing that such relief is justified. The court also noted a key rule: these extraordinary writs are generally not available when a person already has an ordinary, adequate way to challenge the ruling - most commonly, a regular appeal. Here, the court found that Anderson-Alexander did have such an ordinary remedy: she could appeal the custody order. In fact, the court pointed out that she had already filed a timely appeal from that same custody order, and that appeal was pending in a separate case (Docket No. 90813-COA). Because a normal appeal was available and already underway, the court concluded that an emergency writ was not appropriate and denied the petition.

A parent who lost her request to change a child custody and child support arrangement tried to appeal that loss to the Nevada Supreme Court. The Supreme Court looked at the lower court's records and noticed something important: the other parent had filed his own request to change custody (a "countermotion"), and the trial judge had not yet ruled on it. In fact, that request was still scheduled for a hearing in September 2025. Under Nevada's appeal rules, a child custody decision can usually be appealed only after the trial court has finished dealing with all the custody issues in the case. Because part of the custody dispute was still unresolved, the Supreme Court concluded it did not yet have the authority (jurisdiction) to hear the appeal. It dismissed the appeal but noted in a footnote that the appellant may file a new notice of appeal, if she is unhappy with the result, once the district court enters a written order that finally resolves all pending custody issues.

This is a child custody case. After the trial court entered findings of fact and conclusions of law, the father, Troy Heath, tried to appeal that ruling to the Nevada Supreme Court. Before deciding the merits, the Supreme Court checked whether it had the power to hear the appeal at all. In Nevada, parties generally cannot appeal every order a trial court issues - they can only appeal certain types of orders, typically ones that finally resolve an issue. The Supreme Court concluded that the order Heath challenged was only temporary: it set custody on an interim basis and was already scheduled to be reviewed and potentially changed by the trial court. Because the order was not final, the Supreme Court held it had no authority to consider the appeal and dismissed it. Dismissal here is on jurisdictional grounds and reflects nothing about the strength of the underlying custody arguments.

This is a child custody appeal that ended before the Nevada Supreme Court ever considered the merits. Erik Carrillo, representing himself, appealed a Clark County district court ruling that awarded child custody. To move an appeal forward, an appellant must file written arguments - here, a "fast track opening brief," a streamlined written argument required in certain family-law appeals - explaining why the lower court got it wrong. On April 1, 2025, the Supreme Court told Carrillo to file his opening brief by June 2, 2025, and warned him that missing the deadline could result in dismissal. He missed it. On June 11, 2025, the court gave him another 7 days and repeated the warning. He missed that deadline too and, according to the order, did not otherwise communicate with the court. Because Carrillo never filed the brief and never contacted the court, the Supreme Court concluded he had abandoned the appeal and dismissed it. The custody ruling from the district court therefore stands.

Alexander Posey and Margaret Bond, who were previously married, share a minor son referred to as L.P. Under an earlier custody arrangement they agreed to, the parents shared "joint legal custody" - meaning both parents together make major decisions about the child - except that Bond alone made decisions about the child's religious upbringing. In June 2024, Bond asked the court for permission to take L.P. to a child psychiatrist. According to her motion, in April 2024 the child had made troubling statements such as "I want to die and not go to heaven" and "I don't deserve to be alive," although the next day he said he "wanted to live for a thousand years." Bond said the child's former therapist recommended a child psychiatrist, that a teacher reported the child was struggling to focus in class, and that the child's pediatrician indicated a July 10 psychiatry appointment might be the best option. Posey opposed. He agreed the child should see a mental health provider, but he wanted the child to see a new therapist first and let that therapist decide whether a psychiatrist was needed. He said that if the new therapist recommended a psychiatrist, he would follow that recommendation. Because the parents could not agree, Bond asked the court to "break the tie" - a reference to a Nevada Supreme Court case, Kelley v. Kelley, that lets a court decide a health-care question when parents with joint legal custody disagree. While the motion was pending, the parents temporarily agreed to take L.P. to a therapist, and the child attended five sessions. But the dispute over the psychiatrist continued. The district court then issued an order that went further than resolving the psychiatrist question: it gave Bond sole legal custody over the child's mental health generally, including taking him to a psychiatrist, and it ordered that Posey could not make decisions about the child's mental health treatment or obstruct it. The Court of Appeals split its decision. It upheld the part of the order that let Bond take L.P. to a child psychiatrist and any recommended follow-up appointments, finding the district court acted within its discretion because the evidence - including recommendations from the prior therapist and the pediatrician - supported that this was in the child's best interest, and because Posey did not show why a therapist rather than a psychiatrist was better for the child. But the court found that the broader part of the order - giving Bond sole legal custody over all of the child's mental health decisions - went beyond what Bond had actually asked for. Bond's motion sought only the limited authority to take the child to a psychiatrist and follow-ups; she even acknowledged she never sought to strip Posey of his right to be involved in the child's care. Because the court granted this broader control without warning Posey that a wider change to legal custody was being considered, it deprived him of notice and a chance to be heard, violating his due process rights. The Court of Appeals therefore vacated (canceled) that broader part of the order while keeping the psychiatrist authorization intact.

The Nevada Supreme Court dismissed Alfred Clark's appeal in a child custody matter without reaching the merits. The court explained that it could not hear the appeal because of a jurisdictional problem - meaning the court lacked the legal authority to consider the case. Clark's notice of appeal said he was appealing an order filed on April 1, 2025. But when the Supreme Court checked the district court's docket (the official record of filings), no order was filed on that date. The court then considered whether Clark's filing might instead be read as appealing two earlier orders - one from September 10, 2024, and one from November 25, 2024. The problem with that reading is that an appeal must be filed within a specific time after the order being challenged. Because too much time had passed, any appeal of those earlier orders was untimely. When an appeal is filed too late, the Nevada Supreme Court has no power to hear it, so the appeal was dismissed.

Lawana Monday and Maurice Christian share a child born in 2020. They originally had joint legal and physical custody under an agreed parenting schedule, and neither parent paid child support. After Christian moved to Philadelphia, he asked the court to change the arrangement so the child could travel there for extended visits. Monday opposed, saying Christian had not exercised parenting time in over a year, that she had been raising the child alone, and that she also wanted child support. After a hearing, the district court entered an order. The parties agreed (stipulated) that Monday would have primary physical custody, but they did not agree on the parenting time schedule. The district court gave Christian parenting time in Pennsylvania during summers and on alternating holidays. The court also ordered Christian to pay $700 per month in child support - a reduction from the $933 the standard formula would produce, with the $233 reduction accounting for the cost of transporting the child for visits. Monday appealed. She argued the trial court did not make the specific findings Nevada law requires about what is in the child's best interest before changing parenting time. She had raised concerns during the hearing that the child was being evaluated for autism, was in speech therapy three days a week, and that Christian had rarely exercised parenting time and had a problem with alcohol. Christian denied excessive drinking and said he could find a speech therapist in Philadelphia. The Court of Appeals agreed with Monday. Nevada law requires a judge changing custody or parenting time to walk through the statutory "best interest" factors and to tie the decision to specific findings about the child. The district court's written order mentioned the parties' concerns but did not resolve them or analyze the best interest factors. Without those findings, the appellate court said it could not tell whether the result was appropriate. The Court of Appeals reversed the parenting time order and sent the case back so the district court can make the required findings. Because the child support amount had been reduced based on the cost of flying the child to Pennsylvania, the Court of Appeals also reversed the child support order. On remand, the district court must reassess support after it decides the parenting time issue. While the case is back in the trial court, the current custody arrangement remains in place, subject to further modification by the district court.

Megan Sorget and Tyler James Austin were never married but have two children together, born in 2016 and 2018. In November 2020, a court gave the parents joint legal custody (shared decision-making) and gave Sorget primary physical custody (the children lived mainly with her). Shortly afterward, Sorget asked to move with the children to Michigan, and the court allowed it in May 2021, finding that Michigan had a medical center that could help the younger child (L.A.) with his medical conditions. The move was allowed on the condition that Austin would receive generous parenting time. After the move, the parents had ongoing problems working together. Austin filed court motions saying Sorget was keeping the children from him during his scheduled parenting time and was making medical and school decisions without telling him. Eventually, Austin asked the court to change physical custody, return the children to Las Vegas, and order child support. The court held an evidentiary hearing (a trial-like proceeding where the judge hears testimony and reviews evidence) spread across several days. Austin testified that Sorget had denied him parenting time and was interfering with his role as a father. Sorget testified that she believed she was the better parent, that she was more knowledgeable about the children's needs and L.A.'s medical care, and that Nevada had worse medical care and schools than Michigan. She also could not recall whether she had made the children available for all of Austin's court-ordered parenting time. After the first day of the hearing, the court decided it was in the children's best interest to stay with Austin in Nevada, where they already were for his summer parenting time, and it kept those temporary arrangements in place through the rest of the hearing. During the case, Sorget said she would move back to Las Vegas, and by April 2024 she confirmed she had done so. She filed a motion asking for custody, but she did not file a request to have it heard quickly (an "order shortening time") as the court had directed, so the court did not consider that motion at the final hearing day. In its final written order, the court found that circumstances had substantially changed since the earlier custody decision because Sorget had repeatedly violated orders about Austin's parenting time, denied him parenting time, was dishonest about L.A.'s medical treatment, and interfered with Austin's ability to talk to medical providers and make joint decisions. The court also found that several "best interest" factors listed in Nevada law favored Austin. Based on these findings, the court gave Austin primary physical custody, gave Sorget specified weekend and midweek parenting time during the school year plus a week-on/week-off schedule during summer, and ordered Sorget to pay $1,021.21 per month in child support for the two children. On appeal, the Court of Appeals affirmed. It explained that it reviews custody decisions for "abuse of discretion" and accepts the trial court's factual findings if they are supported by "substantial evidence." The court found the trial court's findings were supported by the record — including Austin's testimony, messages between the parties, and an exhibit showing that Sorget herself raised the concern about the child's ability to travel while a neurologist had actually approved the travel. The court noted that a custodial parent's substantial interference with the other parent's parenting time counts as a changed circumstance. It said it does not re-weigh evidence or judge witness credibility on appeal. The court also concluded that the summer week-on/week-off schedule did not turn the arrangement into joint custody because Austin remained the primary custodian for most of the year. Finally, the court declined to address Sorget's brief child-support argument and other undeveloped arguments because she did not support them with adequate argument.

Cierah Johnson and William Bennett divorced in March 2022 and initially shared joint custody of their two daughters on a week-on/week-off schedule. After Johnson's father died, she moved to Colorado, and the parties signed a court-approved stipulation in May 2022 giving Bennett "primary physical custody" of the girls in Nevada, with a note that the parties would "reevaluate the details" in a year. Johnson moved back to Las Vegas in May 2023, and the parents informally resumed week-on/week-off parenting, but Johnson never filed paperwork to change the custody order on the books. Bennett, an Air Force helicopter mechanic, was then ordered to transfer to a base in Georgia. He filed a petition asking the court for permission to take the children with him. Johnson opposed the move, argued that the parties were really exercising joint custody in practice, and filed her own countermotion asking the court to give her primary physical custody. After a three-day hearing, the district court granted Bennett's relocation request. The Court of Appeals identified two main problems with how the lower court got there. First, the lower court decided Johnson's countermotion for primary custody before deciding Bennett's relocation petition. Because Johnson's countermotion was based entirely on the fact that Bennett wanted to move, deciding it first effectively put the burden on Johnson to stop the move - the opposite of what Nevada's relocation statute requires. Second, the lower court used language suggesting Johnson had to do more than show what was "more likely than not" best for the children - it said she had to "significantly tip the scales" and show the children would be "far better off" with her - while at the same time saying Bennett only had to "equal or slightly exceed" what was available for the children in Nevada. That flipped and watered down the legal standards. On the question Johnson pressed hardest - whether the trial judge should have looked past the written custody order and assessed the parents' actual day-to-day arrangement (the "true nature" of custody under the older Rivero case) - the Court of Appeals sided with Bennett. The court explained that Nevada's relocation statutes were rewritten in 2015, after Rivero. Those statutes (NRS 125C.006 and NRS 125C.0065) now key the procedure to whatever custodial arrangement "has been established pursuant to an order, judgment or decree of a court." Because the 2022 stipulation clearly named Bennett as primary physical custodian and Johnson never moved to modify it, the trial court was right to treat Bennett as the primary custodian for purposes of his relocation petition. The Court of Appeals reversed the relocation order and sent the case back so the district court can reconsider Bennett's petition under the correct burden of proof - preponderance of the evidence - and decide his relocation petition before addressing any contingent countermotion by Johnson.

This case is a long-running child-custody dispute between two people who divorced in 2011. Over the years the parents changed their custody arrangement several times. By 2020 they agreed to share joint legal custody (meaning both parents have a say in major decisions about the children) while Carney had primary physical custody (meaning the children live mostly with him). In 2022, Carney raised a serious safety concern: he alleged that the parties' younger child had sexual contact with Probst's stepson (the child of Probst's new husband). The district court temporarily suspended Probst's parenting time, held a hearing, and then required her parenting time to be supervised. The court also barred Probst's husband and stepchildren from attending that time. The parties then agreed to a "safety plan" and to reunification therapy — a process meant to rebuild the parent-child relationship safely. The court appointed Dr. Herbert Coard to evaluate the children and run the reunification therapy, and Dr. Lorraine Apodaca as a "parenting coordinator" — a professional who helps parents resolve smaller disputes. Importantly, the court kept for itself the power to make actual custody changes; it did not give the doctors that power. In early 2023 the court gave Probst unsupervised parenting time, but required it to occur only in the Reno/Sparks area (Probst lives in California). As time went on, new safety concerns surfaced. The younger child reported unwanted physical contact from the stepbrother that Probst allegedly did not stop. Carney then refused to agree to expand Probst's time, and Dr. Coard told Probst he believed she had not addressed the safety problems. Probst filed a motion asking the court to remove Dr. Coard and Dr. Apodaca, claiming they were biased against her, that her parenting time had been wrongly withheld, and that she should get make-up time. The court held a one-day evidentiary hearing at which Dr. Coard testified about his safety concerns and his view that Probst minimized the abuse issue. The court then denied Probst's motion. It found the doctors were not biased but could no longer work with Probst, so it removed them and temporarily acted as parenting coordinator itself. It kept joint legal custody with primary physical custody to Carney, continued Probst's unsupervised parenting time (every other weekend, Saturday 2:00 p.m. to Sunday 4:00 p.m., in the Reno/Sparks area, without her stepchildren), declined to award make-up time, and made Probst responsible for finding a new reunification therapist and paying any additional costs. On appeal, the Court of Appeals affirmed. It concluded that the district court did not improperly hand its decision-making power to the doctors, that substantial evidence supported the finding that the doctors were not biased, that the parenting-time decisions were within the court's discretion and supported by the evidence, that requiring Probst to pay additional therapist costs was not an abuse of discretion, that scheduling a one-day hearing was not arbitrary, and that Probst had not shown the judge was biased against her.

Raymond Bell and Nichole Robinson were never married but have one child together, R.R.B., born in March 2013. The two have been fighting over legal and physical custody of the child almost continuously since 2015. Since an August 2022 court order, they had shared joint physical custody. This appeal was only about physical custody. In April 2023, Bell asked the court to give him primary physical custody, claiming Robinson was abusing drugs and neglecting the child. He supported his request with a statement from Robinson's ex-boyfriend, Bradley Hunt. Many of Hunt's statements about Robinson's alleged drug use were vague about timing or described events that happened before the August 2022 custody order that was still in effect. Bell did describe a January 2023 incident in which, after a party, Robinson allegedly behaved aggressively, bit Hunt on the arm, and then took his car from a police station and damaged it. Robinson disputed most of these allegations. She acknowledged driving away in Hunt's car but said she did so to escape Hunt, who she claimed was threatening domestic violence, and she said any biting was in self-defense. She also said Bell was surveilling her, including hiring private investigators and placing GPS trackers on her vehicle. The district court decided Bell had presented enough to justify a hearing and held an evidentiary hearing in August 2023. Robinson testified that she smoked marijuana two to three times a week but not in front of the child, and denied the other allegations. Hunt testified and repeated his account, but on cross-examination he admitted he had sent Robinson flowers in February 2023 and tried to reconcile in March 2023, even though his written statement said he stopped communicating with her the night of the January fight. He also admitted he never reported Robinson to Child Protective Services despite being involved with her on and off for ten years and claiming to have serious concerns about her parenting. Bell testified but offered few specific allegations about events after the August 2022 order. He admitted making decisions without Robinson's input and providing incomplete or incorrect contact information on school forms. The district court found that the most serious allegations against Robinson were not proven and that much of Hunt's testimony was not credible. The court concluded Bell had not shown a "substantial change in circumstances" that would justify changing custody. The court also reviewed the child's best-interest factors and found that keeping joint physical custody served R.R.B.'s best interest. The court denied Bell's motion. On appeal, the Court of Appeals explained that to change custody a parent must show both a substantial change in circumstances affecting the child and that the change would serve the child's best interest. The court held that the district court's finding — that Bell did not show a substantial change in circumstances — was supported by the evidence. It noted that Bell admitted the private investigator provided no useful information about Robinson's fitness as a parent, and that the domestic-violence factor did not apply because Hunt was not a parent, was not seeking custody, was not living with Robinson, and the child was not present during the altercation. The court also emphasized that it does not second-guess a trial court's decisions about which witnesses to believe, and the district court had found Hunt not credible. Because Bell failed on the first requirement, the appellate court did not need to decide the best-interest question, though it added that Bell had not shown the district court's best-interest findings lacked support. The order was affirmed.

Two parents tried to appeal rulings made in a child-welfare case involving their two minor children. The trial court had substantiated a petition for child protection (a finding that supports continued involvement by Child Protective Services) and had denied the parents' motion asking the court to throw out the case for lack of jurisdiction and alleged conflicts of interest, as well as their request for an order telling Child Protective Services to stop what the parents described as duress, coercion, and unethical conduct. The Nevada Supreme Court did not reach the merits of any of those arguments. Instead, the court explained that appellate courts in Nevada can only hear appeals that a statute or court rule specifically authorizes. The kinds of orders the parents were trying to appeal - orders in ongoing child-welfare proceedings and an order denying a motion to dismiss - are not on the list of orders that can be appealed. Because the Supreme Court had no authority to hear the case, it dismissed the appeal without deciding whether the trial court was right or wrong.

Ronald Harris and Jenniffer Figueroa were married, had four children together, and divorced in 2017. Harris later pleaded guilty to sexually abusing his stepdaughter (Figueroa's daughter from another marriage) and has been incarcerated in Tennessee. In 2020, Figueroa asked the court for sole legal custody (the right to make major decisions for the children) and sole physical custody (where the children live). The court granted both. In earlier appeals, Harris challenged only the legal custody piece; the physical custody arrangement was never litigated on appeal. Later, Harris filed a new motion asking for some form of contact with his children — for example, weekly phone calls, and an order requiring Figueroa to give him the children's address and phone numbers. He said Figueroa had not allowed any contact for about five years and that, in effect, his parental rights were being cut off entirely without anyone considering less drastic options. The district court held a non-evidentiary hearing (a hearing where no testimony or evidence is formally taken) to decide whether a full evidentiary hearing was needed. It treated Harris's request as an attempt to change physical custody, decided the issues had already been resolved in earlier proceedings (a doctrine called res judicata, which bars re-litigating matters already decided), and denied the motion. The Court of Appeals disagreed with how the district court handled this. First, the appellate court said res judicata did not apply, because the earlier appeals had all been about legal custody — not physical custody or Harris's contact with the children. The original custody decree gave Figueroa sole physical custody but never spelled out what contact, if any, Harris was allowed to have. So this motion was actually the first time anyone asked the court to define Harris's contact rights. Second, the court explained that when a parent asks to change physical custody, the court must hold an evidentiary hearing if the parent shows "adequate cause" — meaning a preliminary (prima facie) showing that circumstances have changed and that a change would serve the children's best interest. The court emphasized that Harris was not trying to take physical custody away from Figueroa; he was seeking to define his contact. The court pointed to its 2023 decision in Roe v. Roe, which requires trial courts to make specific written findings when awarding one parent sole physical custody and to consider the least restrictive parenting-time arrangement in the children's best interest. Because the original decree predated Roe and contained no such findings, and because Harris alleged he had been denied all contact, the appellate court concluded Harris had shown enough to warrant a full evidentiary hearing. The appellate court also noted that the district court should have accepted Harris's specific factual allegations as true when deciding whether a hearing was needed, rather than making best-interest findings without taking any evidence. Finally, Harris argued the district judge was biased against him. The appellate court rejected that argument, finding he had not shown the alleged bias came from outside the proceedings or reflected the kind of deep-seated antagonism that would make a fair judgment impossible. The court reversed and sent the case back so the district court can hold an evidentiary hearing and determine what contact, if any, Harris may have with his children, using the framework set out in Roe. The appellate court stressed it was expressing no opinion on whether Harris should actually get contact — only that a hearing is required.

Kasey and Kimberly Loomis married in 2016 and have two young children. In November 2024, Kimberly filed for divorce, asking for sole legal and primary physical custody, with Kasey getting supervised time with the children. Kasey answered, asking for joint legal and joint physical custody. The court scheduled a case management conference (CMC) - an early hearing to organize a case - for February 6, 2025. The notice for that hearing, which was prepared and signed only by Kimberly's lawyer (not by the court), said the court would enter temporary custody orders at that hearing. At the CMC, the parties were sworn in. Kimberly's lawyer said the parents had been sharing a 2-2-3 joint custody schedule, but that Kimberly had concerns about Kasey's mental health. Those concerns stemmed from an incident when Kasey told Kimberly he wanted a divorce; Kimberly alleged that Kasey had removed and hidden her firearm beforehand, and had told the children he was afraid of her and that "mommy was going to jail." The court then questioned Kasey directly. Kasey said he took the firearm because he was scared and it was sitting unsecured, and he acknowledged telling the children he was scared of Kimberly. Based on that questioning, the district court said it had concerns about Kasey's candor, credibility, and mental health. It ordered the children to live only with Kimberly for the time being, with Kasey getting supervised parenting time - one supervised visit per week at the Family Peace Center and one supervised video call per week. The court did not schedule an evidentiary hearing or trial on custody; it set the matter for a settlement conference in July 2025. The court's written order called this "temporary primary physical custody" and said it "expects [Kasey] to obtain a mental health evaluation." Kasey then asked the Court of Appeals for a writ of mandamus - a court order directing a lower court to perform a legal duty or to correct an arbitrary or capricious use of its discretion. The Court of Appeals agreed with Kasey. It held that, although the district court labeled the order "temporary primary physical custody," it was in reality a de facto sole physical custody order, because Kasey was left with no significant in-person time with his children. The court explained that a sole physical custody order requires more findings and more procedure than the district court provided here. The district court's findings - essentially that Kasey's answers were not credible or suggested a mental health issue, plus his admission that he told the children he was afraid of their mother - were "extremely limited." The court made no findings about whether Kasey was unfit to have the children reside with him even briefly, did not explain how such a restrictive arrangement served the children's best interest, did not consider less restrictive alternatives, and did not identify any specific safety or emergency concerns. The court noted this was especially significant because the parents had been sharing joint physical custody for about three months, and Kimberly had never filed an emergency motion for sole custody. The Court of Appeals also held that the district court should have promptly scheduled a trial to finally resolve custody. Under a Supreme Court Rule, custody matters must generally be resolved within six months of when they are contested, unless the court makes specific findings justifying a delay. Here, more than six months had passed since Kasey's answer, and the court had only set a settlement conference - not a trial. The court rejected Kimberly's argument that this was Kasey's fault because he asked for the July settlement conference, explaining that district courts have their own independent duty to resolve custody within six months. Finally, the court addressed the psychological evaluation. The district court's order was vague about whether an evaluation was actually required. But to the extent the court intended to require one, the Court of Appeals held it must follow the procedural rules governing such examinations. The Court of Appeals directed the district court to revisit the temporary sole physical custody award, to immediately schedule a trial to finally resolve custody (or hold an evidentiary hearing on temporary custody if trial would be significantly delayed), and to comply with the applicable rule if it intends to require a psychological evaluation. The court left the current interim custody order in place pending further proceedings.

This is a one-page housekeeping order from the Nevada Supreme Court. The appellant - the person who had asked the Supreme Court to review a lower-court ruling - told the court she no longer wanted to pursue her appeal. The court treated her notice as a request to voluntarily drop the case, granted the request, and closed the appeal. No legal issues were decided. The court did not rule on the underlying child custody dispute or address the merits of anything that happened in the Family Division below.

Claudia Lopez and Sergio Penaloza married in 2015 and had three children, two of whom are still minors. In 2023, Lopez filed for divorce, asking for sole legal and physical custody, alimony, child support, and back child support. She told the court there had been a history of domestic violence. Penaloza asked for joint legal custody but wanted Lopez to have primary physical custody, and he gave conflicting figures about how much money he earned. During the case, both parents repeatedly changed what they were asking for, and the court adjusted the temporary parenting-time schedule several times. Penaloza also asked to lower his child support, saying the couple's oldest child had turned 18, his income had dropped by more than 20 percent, and he could not afford his current payments. At an evidentiary hearing (a hearing where witnesses testify and evidence is presented), the judge asked about domestic violence. The court learned that Lopez had obtained a protective order against Penaloza back in 2005, that Penaloza had no domestic violence conviction, and that the couple had later lived together without any new protective orders. The judge said she would not treat this as a recent history of domestic violence and would not consider it in the custody decision. The court awarded joint legal and physical custody, lowered Penaloza's child support, and decided he owed no back support because he had "been paying for so long" and the couple was "technically still married." The court also declined to award Lopez any alimony. On appeal, the higher court found several problems with the divorce decree. First, when deciding custody, Nevada law requires the judge to go through twelve "best interest" factors and write down findings connecting those factors to the custody decision. The decree here contained no such findings and did not analyze any of the factors. The court also did not make written findings about the alleged domestic violence. For those reasons, the appeals court reversed the joint physical custody award and sent it back for the judge to do the required analysis. Because custody and child support are connected, the appeals court also reversed the child support amount and sent it back to be recalculated after custody is decided. However, the appeals court upheld one specific factual finding: the judge's determination that Penaloza's gross monthly income was $5,000. Penaloza testified his higher past wage was temporary, and he backed that up with pay stubs and a letter from his employer, so the appeals court would not second-guess that finding. The appeals court found the judge made a legal mistake by wiping out Penaloza's child support arrears (past-due support). Under Nevada law, once child support payments become due, they turn into judgments that a court cannot erase or reduce after the fact. At the time of the decree, Penaloza owed $5,388.48 in arrears, so the appeals court reversed the waiver. Finally, the appeals court reversed the denial of alimony. Although the judge mentioned some of the factors the law requires her to weigh, she did not consider all of them - such as the parties' financial conditions, their earning capacities, their standard of living during the marriage, Lopez's career before the marriage, and her contribution as a homemaker. The case was sent back for the judge to consider all of the required factors.

This case is a dispute between two grandmothers over who would serve as legal guardian for a young girl, M.J.V. She was born in 2017 with a radial ray malformation in her right arm (no radial bone or thumb). Because both of her parents had substance abuse issues, her maternal grandmother, Brenda, and step-grandfather, Randy, took her home from the hospital, raised her for roughly five-and-a-half years, and received guardianship over her. During that time they handled all of her medical care, consulted orthopedic specialists, and enrolled her in early intervention programs. About five years later, M.J.V.'s father, Kameron, got sober and gradually re-entered her life. When the district court held a hearing on whether Kameron would regain custody, Brenda and Randy failed to appear, purportedly because they were unaware of the hearing date. The court terminated their guardianship and awarded Kameron custody. Four months later, Kameron died in a work-related accident. After Kameron's death, both grandmothers sought guardianship. Kelly, Kameron's mother, petitioned the day after he died and was awarded temporary guardianship. Brenda and Randy received court-ordered visitation every other weekend and then filed their own competing petition. The relationship between the two households was not positive: Brenda and Randy complained that Kelly restricted visitation to the very letter of the court order and that her communication was "[l]imited and late," while Kelly disagreed with Brenda and Randy's decision to skip M.J.V.'s therapy appointments during their visitation time and believed M.J.V. needed to stay with her for stability. After a three-day evidentiary hearing, the district court awarded guardianship to Brenda, with Kelly receiving visitation every other weekend and on holidays. In a later written order, the court found that both sides loved M.J.V. and were credible but had serious animosity toward each other, and it based its decision on four findings: Brenda would be more likely to facilitate a good relationship between M.J.V. and Kelly; Brenda was better equipped and organized to handle M.J.V.'s medical needs; Brenda could provide better living conditions; and Brenda was in better physical and mental condition to care for M.J.V. Notably, both the GAL (a court-appointed advocate for the child) and the ACORN representative had recommended that Kelly receive the guardianship. On appeal, the Nevada Court of Appeals affirmed. It explained that appellate courts do not reweigh evidence or second-guess a trial court's factual findings so long as those findings are supported by substantial evidence - "evidence that a reasonable person may accept as adequate to sustain a judgment." The court found substantial evidence supporting each of the district court's challenged findings: Kelly had rigidly restricted visitation and communicated sparingly, while Brenda had a history of allowing family contact, including cautiously allowing Kameron back into M.J.V.'s life; Brenda had managed M.J.V.'s medical care for years and kept detailed handwritten records; and Kelly had chronic conditions (fibromyalgia and lupus, with the former requiring doctor-prescribed oxycodone), while Brenda had passed a physical examination as part of a foster-parent vetting process. The court also rejected Kelly's argument that the district court had to walk through the child-custody best-interest factors in NRS 125C.0035(4): those factors may be considered in a guardianship case but are not mandatory. Nor was the district court bound to follow the GAL's and ACORN representative's recommendations - it had to consider them, and it did, but each recommendation is only one factor among many. Finally, although the district court's order used the phrase "sole legal custody" - terminology that ordinarily applies to parents - any mistake in wording was harmless because the guardianship award itself gave Brenda the legal authority to make medical, educational, and similar decisions for M.J.V.

Jon and Melissa Pearson divorced in 2019 and shared their twin sons on a "one week on/one week off" schedule. Both boys have medical needs: one has epilepsy and other conditions, and the other sees a heart specialist for a congenital heart defect. In January 2024, Jon received a job offer from Tesla that required him to move to Austin, Texas. He believed the move offered a significant pay increase, free health insurance, and, based on his research, better schools and medical care for the boys. He asked Melissa to agree to a new custody arrangement so he could relocate with the children; she refused. Jon then filed a motion in court asking to be given primary physical custody so he could move the boys to Texas. When his emergency request was denied, Jon moved to Texas with his current wife and their young son, while the twins stayed in Las Vegas with Melissa pending a full hearing. After an evidentiary hearing, the district court denied Jon's relocation request, awarded Melissa primary physical custody, set a parenting-time schedule for Jon, and ordered Jon to pay monthly child support. The court largely adopted the proposed order that Melissa's attorneys had drafted. Jon appealed. The Court of Appeals reviewed the district court's decision for what the law calls an "abuse of discretion" - meaning a decision unsupported by the evidence, clearly wrong, or made by disregarding the controlling legal rules. The Court of Appeals concluded that the district court made several connected errors. First, the Court of Appeals held that the district court was wrong to find that Jon's move to Texas was not a "substantial change in circumstances" affecting the children. Because the parents could no longer keep the every-other-week schedule once Jon lived in Texas, the children's lives would be affected no matter what the court decided. Second, the Court of Appeals found that the district court applied the wrong legal standard when weighing the move. The court had faulted Jon for not proving that the children's schools and doctors in Las Vegas were "substandard" or inadequate. But under Nevada law, Jon did not have to prove that Las Vegas was bad; he only had to show that the children's needs might be *better* served, or that they would gain an *actual advantage*, by moving to Texas. The district court never made findings on that question. Third, the Court of Appeals held that several of the district court's findings improperly punished Jon for deciding to relocate and for the arguments his lawyers made during the case. Under Nevada law, a court may not use a change of custody as a "sword" to punish a parent's conduct or litigation tactics. Fourth, the Court of Appeals concluded that the district court focused too heavily on keeping things exactly as they were for Melissa, rather than seriously considering whether an alternative parenting-time schedule - Jon had proposed one, plus travel contributions and iPads for communication - could preserve Melissa's relationship with the boys. The court also found the district court's suggestion that Jon might try to "replace" Melissa with his new family was speculative and contradicted by the court's own other findings that both parents had cooperated. Because it was unclear whether the district court would have reached the same result without these errors, the Court of Appeals reversed the order and sent the case back for further proceedings. The Court of Appeals noted that the district court may hold a new hearing to consider the family's current circumstances and the children's wishes, since more than a year had passed and the children would soon turn 13.

When someone files an appeal with the Nevada Supreme Court, they generally must pay a filing fee. If they cannot afford it, there is a separate procedure (governed by a court rule called NRAP 24) for asking to proceed without paying. In this case, Irina Hansen filed an appeal in a child custody dispute against Donovan Hansen but did not pay the filing fee when the appeal was docketed on April 15, 2025. The court sent her a notice the same day giving her 14 days either to pay the fee or to follow the NRAP 24 procedure for proceeding without paying. The notice warned that if she did neither, the appeal would be dismissed. She did not pay and did not respond. The Supreme Court therefore dismissed the appeal without reaching any of the underlying child custody issues.

David Butte and Wendy Rowland are the parents of three children together. Rowland also has a teenage daughter, E.B., from another relationship. Early in this case, both parents asked for sole custody of their shared children, but during an evidentiary hearing they agreed to share joint legal and physical custody, and the court entered an order reflecting that agreement. About nine months later, a different court handling the custody of Rowland's older daughter, E.B., gave sole custody of E.B. to her biological father. That court found that, years earlier—before Rowland ever met Butte—Rowland had moved several times with E.B. without getting permission from the court or E.B.'s father, and it treated those unapproved moves as an abduction for custody purposes. Butte was not part of that case. After learning of that ruling, Butte went back to the court handling his own children's custody and asked it to reconsider the joint-custody arrangement. He relied on a Nevada statute that lets a court reconsider a custody order if it is later determined that a parent committed an act of abduction. Butte argued that if he had known the details of Rowland's earlier moves with E.B., he never would have agreed to share custody, and he asked for sole custody of the parties' children. At a hearing, both parents testified. Rowland explained that she had moved with E.B. to New Zealand because E.B.'s father did not want to be involved and had been abusive to her; she and E.B. were later deported back to the United States and eventually settled in Reno. She disputed the other court's finding that she had abducted E.B. but acknowledged she no longer had custody of that child. Butte testified that he had known Rowland relocated to New Zealand with E.B. before he agreed to joint custody, but said he did not know the surrounding circumstances until the other court ruled. He also admitted that he and Rowland had been successfully sharing custody of their children for about two years without significant problems. The trial court acknowledged that another court had found Rowland committed an act of abduction as defined in the statute. Nevertheless, the court decided that the legal presumption against joint custody in abduction cases had been overcome for three reasons: the parents had been sharing joint custody without incident since 2023; a county human-services investigation found both parents were safe placements for the children; and Butte had agreed to joint custody even though he already knew Rowland had relocated to New Zealand with E.B. The court then reviewed the statutory factors used to decide a child's best interest and concluded that keeping joint custody was best for the children. It denied both parents' requests to change custody. On appeal, the Court of Appeals affirmed. It explained that the presumption against joint custody in abduction cases can be rebutted, and here the trial court found it was rebutted. Butte challenged only one of the three grounds the trial court relied on—the fact that he had agreed to joint custody. Because he did not challenge the other two grounds (the two years of successful shared custody and the human-services finding that both parents were safe placements), the appeals court treated those unchallenged grounds as waived and sufficient to support the ruling. Butte also did not challenge the trial court's analysis of the best-interest factors, so those findings stood as well. Finding no abuse of discretion, the court upheld the denial.

This case arose from an ongoing dispute in a Nevada family court about changing a child custody arrangement. One parent, Jacob Sovey, asked the Court of Appeals to step in before the family court case had finished. He did this by filing an "emergency petition for a writ of mandamus or prohibition" - a request for a special court order that either forces a lower court to do something it is legally required to do (mandamus) or stops it from doing something it is not allowed to do (prohibition). These are considered extraordinary remedies, meaning courts only grant them in unusual situations. The Court of Appeals reviewed the petition and the documents supporting it and decided not to intervene. The court explained that the person asking for this kind of relief has to carry a heavy burden of showing that such extraordinary intervention is justified, and that Sovey had not met that burden. The court also pointed out that Sovey has another path available to him. If he is unhappy with the family court's final decision on the custody modification once the evidentiary hearing (a court hearing where evidence is presented and witnesses may testify) is complete, he can file a regular appeal at that point. Because that ordinary route exists, the court declined to use its discretion to take up the emergency petition and denied it.

This case involves a custody dispute over V., a child born in May 2019 to Terry Rosser and Joan Taylor, who briefly dated but never married. According to the opinion, Rosser initially told Taylor she would be the child's primary caregiver, at one point during the pregnancy tried to self-terminate his parental rights, and eventually stopped communicating with Taylor. He was not present at the birth and sent only three messages over the next year. In April 2020, Rosser filed a complaint seeking joint legal and physical custody; Taylor counterclaimed for primary physical custody, sole legal custody, and child support, including retroactive child support. The trial was continued seven times and finally took place in November 2023. In the intervening years, problems accumulated. Rosser missed a large share of his scheduled parenting time - Taylor estimated more than 100 missed exchanges, over half his parenting time, and Rosser himself testified he missed dozens of visits. He refused to cooperate meaningfully in discovery (the pretrial exchange of evidence), refused during his deposition to say how much money he earned, and sent blank HIPAA authorizations when Taylor requested his medical records. He also fell behind on the $84 monthly temporary child support and refused to pay Taylor directly because he "just didn't want to interact ... with the mother at all." At trial, Rosser - who had been diagnosed with cancer - stipulated (formally agreed) that Taylor would have primary physical custody, but he still sought joint legal custody and requested four days a week of three unsupervised hours of parenting time. He also testified that he "[chose] not to [work], let's put it that way," that his father gave him over "six figures" each year, and that the court could impute (attribute) $4,000 to $5,000 a month of income to him. The district court awarded Taylor primary physical custody, gave Rosser two days a week of four-and-a-half unsupervised hours each, plus every Father's Day and Christmas Day and every other Thanksgiving and Easter, and granted Taylor sole legal custody after finding the parties' communication and cooperation were dysfunctional. It imputed Rosser's income at $8,333 per month, set child support at $1,147 per month, ordered $56,507 in retroactive support, required Rosser to pay the remaining medical expenses of V.'s birth and half of her health insurance, and awarded Taylor $60,000 in attorney fees. The Nevada Court of Appeals affirmed on every issue. It held that substantial evidence - evidence a reasonable person would accept as adequate - supported the finding that the parents' dysfunction rebutted the presumption favoring joint legal custody, pointing to the district court's findings that Rosser was dishonest and not credible, had long absences from V.'s life, and "views disagreement on nearly all issues involving [V.], many of which are trivial, [as] a game." On parenting time, the court noted Rosser had never exercised more than three hours a day and had missed a significant amount of his pretrial time; it also observed that the nine hours per week awarded nearly matched the twelve hours he requested, "which is akin to invited error" - a doctrine barring a party from complaining on appeal about something he asked for. The court rejected Rosser's argument that his schedule was really "sole" rather than "primary" physical custody, explaining that his time is unsupervised, occurs twice weekly, and includes holidays - unlike the highly restrictive arrangements that define sole physical custody. On money issues, the court held the imputed income was supported by Rosser's own testimony, that retroactive support was permitted (Taylor sought it when V. was one year old, and the statute allows recovery of up to four years of support furnished before the action), and that the statute making "[t]he father ... also liable to pay the expenses of the mother's pregnancy and confinement" is clear and unambiguous. Finally, the attorney fee award was upheld because the district court reviewed the required reasonableness factors and awarded significantly less than the $100,434.81 Taylor requested. A request to reassign the case to a different judge was deemed moot because the case was not being remanded and the trial judge no longer serves on the district court bench.

Jessie Elias Baca asked a Clark County family court to change the custody arrangement for his minor child. The family court declined to modify custody, and Mr. Baca - representing himself, without a lawyer - appealed that decision to the Nevada Supreme Court. When someone files an appeal, the Supreme Court requires the appellant to take certain procedural steps: telling the court whether transcripts of the lower-court hearings will be ordered, filing a "docketing statement" (a basic information form about the case), and filing an opening brief explaining why the lower court got it wrong. On February 3, 2025, the court sent Mr. Baca a notice setting deadlines for each of these items. Mr. Baca missed the deadlines. On March 21, 2025, the court issued a follow-up order giving him another 14 days to file the missing documents and warning him that the appeal could be dismissed if he did not comply. He did not file the documents. He also did not file the opening brief by its April 4, 2025 deadline, and he did not contact the court at all. Concluding that Mr. Baca had abandoned the appeal, the Supreme Court dismissed it. The dismissal ends this appeal; the family court's order refusing to modify custody remains in place.

This case involved a child custody dispute. After the family court denied Richard Cruz's request to reconsider its ruling, Cruz appealed to the Nevada Supreme Court. While the appeal was pending, his attorney asked to stop representing him, and the Supreme Court allowed the attorney to withdraw. When a party loses their lawyer during an appeal, they must either hire a new lawyer or tell the court they will represent themselves (proceed "pro se"). On January 17, 2025, the Supreme Court ordered Cruz to do one of those two things within 30 days, and warned him that failing to do so could cause his appeal to be thrown out. Cruz did not respond. The court gave him a second chance on March 11, 2025, allowing him 14 more days and repeating the warning. Cruz again did not respond. Because Cruz did not communicate with the court at all, the Supreme Court concluded that he had abandoned his appeal and dismissed it. That dismissal ends his appeal; the family court's underlying custody ruling stands.

This is a very short procedural order. When someone files an appeal with the Nevada Supreme Court, they generally have to pay a filing fee, or else formally ask to proceed without paying it by following a specific court rule. In this case, the appellant - Alicia Kay Glenny - docketed her appeal in a child custody case but did not pay the filing fee. The Supreme Court sent her a notice the same day the appeal was docketed, telling her she had 14 days either to pay the fee or to show that she qualified to proceed without paying it. The notice warned that if she did not comply, her appeal would be dismissed. According to the order, she did not pay the fee and did not otherwise respond. Because of that, the court dismissed the appeal. The order does not address the underlying child custody dispute on the merits.

This is a child-custody dispute that never reached the merits in the Nevada Supreme Court. The trial court entered an order that did two things: it denied Angelo Smith's request to pause (abate) the case, and it set up temporary custody and support arrangements. Smith tried to appeal that order directly to the Nevada Supreme Court. The Supreme Court dismissed the appeal without addressing the underlying custody questions. The reason is jurisdictional: in Nevada, a party can only appeal when a statute or court rule specifically allows an appeal from that type of order. Here, the order Smith challenged was a temporary custody order and a denial of a motion to dismiss - neither of which the law lets a party appeal right away. Final custody orders can be appealed; temporary ones generally cannot. Smith offered two theories for why his appeal should be allowed anyway. First, he invoked the "collateral order doctrine," a federal concept that lets parties appeal certain side-issue rulings before a case ends. The Nevada Supreme Court noted that it has not adopted that doctrine. Second, he argued the order was appealable as a denial of a motion to dismiss, citing a case called Ducharm v. District Court. The court stated it could not locate that case. Under Nevada precedent, denials of motions to dismiss are not appealable. Because no statute or rule authorized the appeal, the court dismissed it and denied Smith's pending motion for a stay as moot.

This order resolves a jurisdictional question in one of two related child custody appeals. The father, Edgar Tavares, had appealed a district court order from April 15, 2024 that modified child custody. While that appeal was pending, the district court signaled it wanted to fix something in the April order using a procedural rule (NRCP 60(a)) that allows correction of clerical-type errors. Because an appeal was already up at the Supreme Court, the district court could not act on its own; it had to issue what is called an "indicative order" under NRAP 12A - essentially a written statement that, if the Supreme Court sent the case back briefly, the district court would make the correction. The Supreme Court did send it back temporarily, and the district court entered a corrected order on November 4, 2024. Tavares then filed a separate appeal (Docket No. 89473) from the September 5, 2024 indicative order. The Supreme Court told him to explain why that appeal should not be thrown out for lack of jurisdiction, because no statute or rule allows a party to appeal an indicative order under NRAP 12A - it is just a signal of what the district court would do, not a final ruling that changes anyone's rights. Tavares argued the district court had gone beyond what NRCP 60(a) allows, so the limited remand was ineffective. The Supreme Court said those are arguments about whether the district court got it right on the merits, not arguments showing the Supreme Court has jurisdiction to hear an appeal in the first place. Because no rule authorizes an appeal from an NRAP 12A indicative order, the court dismissed Docket No. 89473. The other appeal (Docket No. 88561), challenging the underlying custody modification, is still alive. The Supreme Court noted that Tavares can raise his concerns about the September 5 and November 4 orders within that pending appeal. With the second appeal dismissed, the motions to combine the two appeals were moot.

This is a procedural dismissal, not a decision on the merits of the underlying child custody dispute. When someone files an appeal in Nevada, the rules require that the notice of appeal be served on the other parties and that proof of that service be filed with the court. Mr. Casillas filed his notice of appeal on December 26, 2024, but did not include the required proof of service. The Supreme Court gave him two chances to fix the problem. On the day the appeal was docketed, the court sent a notice telling him to provide proof of service within 14 days and warned that not doing so could result in dismissal. When nothing was filed, on February 4, 2025, the court issued a second order giving him another 14 days and again warning that the appeal would be dismissed if he did not comply. He still did not comply, so the court dismissed the appeal. The dismissal means the appeal is over without the court ever reviewing the underlying custody ruling. The opinion does not address the merits of the custody dispute.

Khalifa and Madeline Burden were never married but share one child. Over many years, the parents fought repeatedly in court over custody and how to raise the child. Custody arrangements changed several times: joint custody at first, then primary physical custody to Khalifa in 2015, then joint physical custody again in 2019, and continued joint custody with a week-on/week-off schedule after a 2020 order that also chose Burden's preferred elementary school over Khalifa's preference for homeschooling. Later, Burden asked the court to change custody again. She alleged that circumstances had changed in a way that hurt the child - specifically, that Khalifa had emotionally abused the child by telling her to lie at school and by telling her that it was her fault she had been sexually abused in the past. The court held an evidentiary hearing (a hearing where witnesses testify and evidence is presented) at which both parents testified. Burden described an incident on December 13, 2022, in which the child was very upset after being with Khalifa. The court allowed Burden to repeat what the child said that day, treating those statements as "excited utterances" - an exception to the usual rule against repeating someone else's out-of-court statements, applied when a person is speaking under the stress of a startling event. According to that testimony, Khalifa had wanted the child to lie to school officials, became angry when she would not, made her stay outside in the cold, told her he did not want her anymore, said she had "demons inside her," and blamed her for being sexually abused. Khalifa denied making those statements and testified that he wanted the child homeschooled or in a program with remote learning, and that he did not want the child in therapy because it was against his religious beliefs. The district court found that circumstances had substantially changed - including Khalifa's emotional abuse of the child - and that the child's best interest favored giving Burden primary physical custody. The court kept joint legal custody (shared authority over major decisions) but gave Burden the final say on schooling and mental health treatment. It also decided the child should stay at her current middle school rather than be homeschooled, and it limited Khalifa's parenting time to short, gradually increasing visits, with the possibility of more time if he behaved appropriately. On appeal, Khalifa argued the court wrongly modified custody, ignored the child's emotional suffering from reduced time with him, failed to properly weigh the child's past sexual abuse, wrongly gave Burden authority over mental health decisions, wrongly rejected homeschooling, and should have disqualified the judge for bias. The Court of Appeals rejected each argument, holding that the district court's findings were supported by the evidence and that an appeals court does not re-weigh evidence or re-judge witness credibility. It affirmed the district court's order in full.

This is a child-custody case from Washoe County. One parent, Samantha Herrick, asked the family court to change the existing custody or visitation arrangement. The district court reviewed the parents' arguments and decided that Herrick had made a preliminary showing that something had changed substantially in the children's lives - enough to justify holding a hearing to consider whether the custody arrangement should actually be modified. The court did not yet change custody; it just scheduled the matter for a hearing. The other parent, Jacob Sovey, tried to appeal that order to the Nevada Supreme Court right away. The Supreme Court dismissed the appeal because, under Nevada's appellate rules, parties generally cannot appeal every order a trial court issues - only those orders that a statute or court rule specifically allows to be appealed. An order that merely sets a hearing on a request to modify custody is not on that list. The Supreme Court explained that because the district court has not yet decided whether to actually change the custody arrangement, there is nothing final for the Supreme Court to review. Because the appeal was dismissed for lack of jurisdiction, Sovey's separate request to pause (stay) the lower-court proceedings was denied as moot - meaning there was no longer anything for the Supreme Court to act on.

Cheyenne Soldo-Allesio and Kevin Alan Ferguson were never married but share a young child, E.F. After their final separation in February 2022, Soldo-Allesio obtained a temporary protective order (TPO) - a short-term court order intended to protect a person from alleged abuse - against Ferguson based on allegations of domestic violence and moved with E.F. to Florida. Ferguson then filed for primary physical custody in Nevada. Soldo-Allesio responded that Ferguson had a long history of domestic violence, attaching exhibits including the TPO and its extension, police reports, and photos of injuries. At trial, the district court excluded all of Soldo-Allesio's exhibits, mainly because she disclosed her trial exhibit list only three days before trial. Soldo-Allesio still testified about several incidents of alleged abuse. The court ultimately found there was no "clear and convincing evidence" of domestic violence and largely awarded the custody outcome Ferguson requested. Soldo-Allesio asked the court to reconsider, arguing it had used the wrong burden of proof on the domestic violence question and had wrongly thrown out all her exhibits. The district court denied that motion. The Court of Appeals reversed. It explained that Nevada law uses two different burdens of proof when domestic violence comes up in a custody case. To trigger the legal "rebuttable presumption" - a starting assumption a parent can try to overcome - that an abuser should not get custody, the abuse must be proven by "clear and convincing evidence" (a high standard). But when the court is simply weighing domestic violence as one of the statutory "best interest" factors used to choose a custody arrangement, the standard is the lower "preponderance of the evidence" (more likely than not). The district court used the higher standard for both purposes, which the Court of Appeals held was legal error. The Court of Appeals also held that the district court was wrong to suggest Soldo-Allesio needed to show Ferguson had been criminally convicted of domestic violence. A criminal conviction is not required to prove domestic violence in a civil custody case; a victim's testimony alone can be enough. Finally, the Court of Appeals concluded that excluding all of Soldo-Allesio's exhibits effectively was a discovery sanction, and the district court did not follow the rules (NRCP 16.205(g) and NRCP 37(c)) governing such sanctions - rules that require the court to consider whether the failure to disclose was justified or harmless and whether exclusion is an appropriate penalty. That mattered especially because some of the excluded exhibits had already been served on Ferguson earlier in the case, and because the Nevada Supreme Court has said courts must hear "all information regarding domestic violence" when deciding what is best for a child. The case was sent back to the district court to apply the right legal standards and reconsider the evidence.

Two parents tried to appeal a Nevada family court ruling that gave Clark County Family Services temporary custody of their five children. They filed the appeal themselves, without an attorney. The Nevada Supreme Court did not reach the merits of whether the temporary custody order was right or wrong. Instead, the court explained that it can only hear appeals when a statute or court rule specifically allows them. Because no statute or rule allows an appeal from a temporary custody order entered under Nevada's child welfare statutes (NRS Chapter 432B), the court concluded it had no power - no "jurisdiction" - to consider the appeal at all, and dismissed it. The court also noted a procedural concern about how the State served its motion to dismiss on the parents. The State's certificate of service said the parents were served "and/or" by email, but the rules require that a party consent to email service before it can be used. The court flagged that using "and/or" in a certificate of service is "strongly discouraged" because it leaves the manner of service unclear. Because the appeal was being dismissed on jurisdictional grounds, however, the State's motion to dismiss and the parents' motion for a stay were denied as moot.

Stephanie Vivas, representing herself, tried to appeal a Clark County family court decision about child custody involving David Ramos. While the appeal was pending, the Nevada Supreme Court paused the case and asked the lower court to first rule on a motion Vivas had filed asking the family court to undo its own ruling. The family court then issued an order saying it would treat Vivas's motion as a request to amend its decision, granted that request, and announced it would issue a new, modified custody and visitation order. Because the original ruling Vivas was challenging is being changed by the family court itself, the Supreme Court concluded there was nothing left for it to fix on appeal - the case is "moot," meaning the court can no longer give meaningful relief about the original order. The Supreme Court therefore dismissed the appeal. The dismissal is "without prejudice," which means Vivas (or Ramos) can file a new appeal from whatever new custody order the family court eventually issues, if either of them disagrees with it.

This is a one-page housekeeping order from the Nevada Supreme Court. Alfred Clark filed an appeal but did not pay the filing fee that is normally required to start an appeal. He also did not file the paperwork that would let him proceed without paying the fee (a process governed by a court rule called NRAP 24, which covers permission to appeal "in forma pauperis," meaning as a person who cannot afford the fee). The court sent Clark a notice telling him he had 14 days to either pay the fee or show that he qualified to proceed without paying. The notice warned him that if he did neither, his appeal would be thrown out. According to the order, Clark did not pay and did not respond. The court therefore dismissed the appeal without ever reaching the merits of whatever child-custody issue Clark was trying to raise.

This case involves a grandmother, Donna Gilmore, who asked a family court to make her the legal guardian of her three-year-old granddaughter. A guardianship is a legal arrangement in which a court gives one person the authority and responsibility to care for another person who cannot fully care for themselves - here, a young child. Gilmore filed her petition in May 2023. She claimed the child's mother, Monica Fears, could not properly care for the child because Fears was often homeless, lacked steady work and a vehicle, and had a substance abuse problem. She also noted that the child's father was in jail and could not care for the child. Gilmore said the child had been living with her since May 2022, and she asked the court for temporary guardianship until the case was decided. The court granted the temporary guardianship while it looked into the situation. The court later held an evidentiary hearing - a hearing where witnesses testify and evidence is presented so the judge can make findings of fact. Both women testified. Gilmore said she often babysat the child while Fears worked and disagreed with Fears' choices about who else babysat the child. Fears testified that the child had not moved in with Gilmore; instead, Gilmore had simply been the babysitter while Fears worked night shifts. Fears said she had a full-time job as a restaurant server, also worked part-time as a tattoo artist, had a residence, took the child to medical care when needed, and had a plan for childcare through a housemate. Fears denied having a substance abuse problem. She also explained that she had fainted at work in May 2023 (later diagnosed as a syncope, a temporary loss of consciousness) and was hospitalized, after which Gilmore filed for guardianship and kept the child from her. Under Nevada law, the person asking to become a guardian must prove that the guardianship is necessary by "clear and convincing evidence," which is a demanding standard of proof. The district court found Gilmore did not meet that standard. The court found there was no evidence that Fears could not provide the child's basic needs, no evidence Fears had a drug or alcohol problem, and no evidence of crimes or domestic violence. The court also found that Gilmore had not proven the child was out of Fears' care for the six months before the petition was filed, so a legal presumption that a parent is unsuitable (which can apply when a child has been out of a parent's care for that long) did not apply. Because Gilmore did not prove Fears was unsuitable or that a guardianship was necessary, the court denied the petition and directed that the child be returned to Fears. On appeal, Gilmore argued the court got the facts wrong and that it should have found Fears unfit and found that the child had lived with her since May 2022. The Court of Appeals explained that it generally does not re-weigh evidence or second-guess the trial judge's decisions about which witnesses to believe. It concluded that the district court's findings were supported by the evidence. Gilmore also argued the judge was biased - that the judge asked demeaning questions, used a condescending tone, and had made up her mind before hearing all the evidence. The Court of Appeals rejected this claim, explaining that a judge's rulings and conduct during a case generally do not show disqualifying bias unless they stem from something learned outside the courtroom or reveal deep-seated hostility that would make a fair decision impossible. The court found the record showed the judge listened to the testimony and considered the evidence. The Court of Appeals affirmed the district court's decision.

Mason Pais and Grecia Corral were never married but have one young child together, born in December 2021. In August 2022, Pais went to court asking for joint legal and physical custody. Corral responded by asking for sole legal and physical custody. While the case was pending, the court temporarily ordered joint legal and physical custody until it could hold a hearing. At a November 2023 evidentiary hearing (a court proceeding where both sides present evidence and testimony), the district court made its findings out loud, on the record, and decided the parents would share joint legal custody but that Corral would have primary physical custody. The written custody decree (the court's formal written order) was entered in January 2024. That decree also required Pais to pay $394 per month in child support. Pais then filed a motion asking the court to change its decision or grant a new trial. Among other things, he argued that the court never put its reasoning into writing and never made written findings about the twelve "best interest" factors that Nevada law requires a court to consider when deciding child custody. The district court denied his motion, explaining that it had considered those factors and stated its findings out loud at the end of the hearing. The Court of Appeals reversed. The core problem, the court explained, is that a written custody decree must actually contain the court's findings about the child's best interest and must connect those findings to the custody decision. Here, the written decree contained no such findings and did not address any of the twelve statutory factors. Even though the district court may have discussed the factors out loud during the hearing, the appeals court held that spoken findings are not enough - the written order itself has to include them. Because the written decree lacked these findings, the Court of Appeals concluded the district court abused its discretion, reversed both the custody decree and the order denying Pais's motion, and sent the case back for further proceedings. In the meantime, the existing custody arrangement stays in place unless the district court changes it. The appeals court also noted that, because it reversed the custody decree, the district court may need to revisit both the child support amount and any award of attorney fees.

Kathryn and Brian Mead divorced in 2007 and shared joint physical and legal custody of their three children. In 2022, the district court gave Brian primary physical custody of the youngest child (the only one still a minor) and awarded him child support. Kathryn appealed, and in an earlier decision (called Mead I), the Court of Appeals reversed that order. The appeals court found that the district court had not made the required finding that circumstances had substantially changed, and had not analyzed the "best interest of the child" factors set out in Nevada law before changing custody. The case was sent back to the district court. On remand, the district court set a hearing on custody and support for the youngest child and, in the meantime, ordered the parents to share the child on a week-on, week-off basis. Before that hearing, Kathryn asked the court to give her primary physical custody. She said that in February 2024 Brian's house had burned down, that the child had been living with her full time, and that Brian could not properly care for the child in a home that (she alleged) had no working kitchen, toilets, or electricity. The district court found there was "adequate cause" to hold an evidentiary hearing on the issue, but then orally denied Kathryn's motion before the scheduled hearing. At the evidentiary hearing, the district court analyzed the best-interest factors and concluded that joint physical and legal custody was best for the child. On money matters, the court found Brian earned $6,000 a month and imputed (attributed) income of $3,000 a month to Kathryn. Based on that, Brian would owe Kathryn $480 a month in child support until the child reached adulthood and finished high school. But because Kathryn owed Brian $5,242 in past-due amounts (arrears), the court had Brian pay a single lump sum of $518 instead. Kathryn appealed again. She argued the court failed to weigh her arguments about the house fire, that she had shown a strong case for primary custody, and that the court made mistakes in handling the evidence and in using older (2013) income figures rather than more recent financial documents. The Court of Appeals did not reach the merits of most of these arguments. The reason was practical: Kathryn did not order and file the written transcripts of the two key hearings (the April 3, 2024 hearing on her motion and the May 23, 2024 evidentiary hearing), even though the supreme court had notified and instructed her to do so. Without those transcripts, the appeals court said it could not review what actually happened or why the district court ruled as it did. Under an established rule, when an appealing party leaves necessary records out, the court assumes the missing material supports the lower court's decision. Because the district court's written order showed it had considered the best-interest factors and made findings on the support issue, the appeals court concluded there was enough evidence to support the rulings and affirmed them.

Alicia and Richard Young divorced after having one child together, born in 2016. Under the divorce decree, they shared joint legal custody (joint decision-making authority), Alicia had primary physical custody (the child lived mainly with her), and Richard had parenting time every other weekend plus a midweek evening on alternating weeks. Richard later filed several motions alleging that Alicia was not following the custody arrangement and was denying him his parenting time, including overnight visits. Before a scheduled evidentiary hearing, the parties reached a new agreement: Alicia would keep primary physical custody, the child would continue seeing her therapist, and a "parenting coordinator" - a court-appointed professional who helps parents resolve day-to-day custody disputes - would be appointed and would aggressively promote expanding Richard's parenting time. The court's appointment order let the coordinator resolve disputes about the custody arrangement but did not permit her to make substantive changes to it, and it told the parties that the coordinator's decisions were not final and could be reviewed by the court. About two months later, the parenting coordinator reported to the court that Alicia had blocked efforts to reunify the child with Richard and refused to bring the child to therapy appointments, and that she believed Alicia's actions had become abusive and neglectful of the child's mental health needs. After further proceedings, the district court temporarily placed the child in Richard's care for 18 days. When the parties tried to resume the prior arrangement, more problems arose, and Richard moved to modify custody, alleging that Alicia interfered with his relationship with the child, withheld the child, coached the child to falsely allege abuse, skipped the child's therapy sessions, and refused to cooperate with the parenting coordinator. Alicia opposed the motion and asked the court to disqualify the parenting coordinator for bias and overstepping her authority. At an evidentiary hearing, Richard, Alicia, and the child's therapist testified. The therapist described the child's anxiety and said, among other things, that Alicia often failed to bring the child to therapy, that the child kept a food log and was weighed before and after her time with Richard, that the child looked to Alicia for confirmation when making statements, and that Alicia's actions had a negative impact on the child. The district court found a substantial change in circumstances - in particular, Alicia's actions causing parental alienation between Richard and the child and interference with the child's therapy - found that several statutory "best interest" factors favored Richard, and awarded Richard primary physical custody while keeping joint legal custody and giving Alicia specified overnight parenting time. The court also declined to disqualify the parenting coordinator. The Nevada Court of Appeals affirmed. It held that the district court's factual findings were supported by substantial evidence from the hearing testimony. As to Alicia's complaint that the court considered the parenting coordinator's reports, the appellate court noted that the district court did not specifically rely on those reports in its custody findings, and that even assuming it was error to consider them, Alicia did not show the error was prejudicial rather than harmless, given the extensive testimony from Richard and the therapist. The court also rejected the argument that the district court improperly handed its decision-making power to the parenting coordinator, because the court retained ultimate authority over custody and made its own findings. Finally, the court concluded the district court did not abuse its discretion in finding the parenting coordinator was not biased and did not overstep her authority.

Matthew Walker asked the Nevada Supreme Court to step in and overturn a decision by a family court judge who denied his request to establish visitation with a child. Instead of filing a regular appeal, he asked the Supreme Court for an "extraordinary writ" - either a writ of mandamus (a court order requiring a lower court to do something it must do) or a writ of prohibition (a court order stopping a lower court from doing something it cannot do). The Supreme Court declined to get involved. It explained that these extraordinary writs are reserved for situations where a person has no other reasonable way to fix the problem in court. Here, the order Walker was challenging was a "final appealable order," meaning he could have appealed it through the normal appeal process. Because a regular appeal was available to him, the Supreme Court concluded that writ relief was not the right tool. The court also noted that a writ cannot be used as a substitute when someone has missed the deadline to file a normal appeal. The court did not rule on whether the family court judge was right or wrong about visitation. It only decided that this particular procedural vehicle - a writ petition - was not the proper way to bring the issue before the Supreme Court.

This is a short, jurisdictional ruling. While a divorce case was still pending in district court in Elko County, one of the parties, Lauren Taylor Fisher, filed an ex parte motion (a request made to the judge without the other side present) about a "pickup" issue. The district judge denied that motion. Ms. Fisher, representing herself, then tried to appeal that denial to the Nevada Supreme Court. The Supreme Court did not reach the merits of the dispute. Instead, it explained that it can only hear appeals that some statute or court rule specifically allows. Because no statute or rule permits an appeal from this kind of pre-decree order denying an ex parte motion, the court concluded it had no power to hear the case and dismissed the appeal. In practical terms, the underlying divorce case continues in the district court; the Supreme Court's order simply means it could not step in at this stage.

This is a one-page housekeeping order from the Nevada Supreme Court, not a ruling on the merits of any custody dispute. When someone files an appeal in Nevada, they must submit a "docketing statement" - a standardized form that gives the court basic information about the case. Alfred Clark filed one, but it did not meet the court's requirements. On November 15, 2024, the Supreme Court struck Clark's deficient docketing statement and gave him 14 days to fix it and re-file. The court warned that if he did not, his appeal would be dismissed. He did not file a conforming docketing statement within that deadline, and on December 11, 2024, the court dismissed the appeal. The court did not address the underlying child custody questions.

Paul and Jennifer Martinez divorced in California in 2015 and share a child, L.M. Jennifer received primary physical custody, and the parents shared joint legal custody. Jennifer later moved with the child to Nevada with court permission, and the case eventually transferred to Nevada courts. After further disputes, the Nevada district court increased Paul's visitation time and ordered Jennifer to pay all the costs of transporting L.M. to and from visits with Paul, reasoning that because Jennifer was the parent who moved away from California, she should bear those costs. Jennifer challenged two parts of that ruling: the order making her pay 100% of travel costs, and the decision to expand Paul's visitation beyond what the parties had specifically asked the court to address. On the travel-cost issue, the Nevada Supreme Court agreed with Jennifer. Nevada has a detailed administrative regulation, NAC 425.150, that lists factors a court must consider before adjusting child support away from the standard formula. One of those factors is the cost of transporting the child for visitation. The Court held that a district court cannot simply impose all travel costs on one parent as a stand-alone order; instead, those costs must be evaluated as part of the overall child support analysis, looking at the child's needs and both parents' financial circumstances. The district court's reliance on the fact that Jennifer had moved years earlier, by itself, was not a proper basis for assigning her all the costs. On the visitation issue, the Court sided with the district court. Although Jennifer argued she did not have fair notice that the court might broadly change the visitation schedule, the Court found she had put visitation squarely before the court (by asking that Paul's visits be supervised), testified at length on the topic, and had the chance to present evidence. The Court also found enough evidence in the record - including doctor notes and Paul's own testimony - to support letting Paul have a standard out-of-state unsupervised visitation schedule. The Court reversed the travel-cost portion of the order and sent the case back to the district court with instructions to apply the NAC 425.150 framework. It affirmed everything else and declined to sanction Jennifer for bringing the appeal.