Nevada family-law case summaries

This is a brief procedural order, not a ruling on the merits of the underlying child custody dispute. The person who filed the appeal, Danieli Bueno Navon, asked the Nevada Supreme Court to dismiss her own appeal. The other side did not oppose that request. The Supreme Court granted the request and dismissed the appeal under NRAP 42, the Nevada Rule of Appellate Procedure that governs voluntary dismissals of appeals. Because the appeal was voluntarily dismissed, the Supreme Court did not decide any of the custody issues that the appeal might have raised. The opinion does not describe the underlying facts, the district court's ruling, or the grounds the appellant had intended to argue.

This is a one-page clerk's order from the Nevada Supreme Court dismissing an appeal before the court ever reached the merits. When someone files an appeal, they generally must pay a filing fee or qualify for a waiver of that fee. Here, the appellant filed her appeal but did not pay the fee. The court sent the appellant a notice on the same day the appeal was docketed, telling her she had 14 days either to pay the fee or to show that she qualified for a fee waiver under the applicable appellate rule. The notice warned her that if she did neither, her appeal would be dismissed. According to the order, she did not respond at all. The court then dismissed the appeal. This order does not decide anything about the underlying guardianship dispute over the minor R.O. It addresses only the appellant's failure to satisfy a procedural prerequisite to having her appeal heard.

This is a brief administrative dismissal, not a ruling on the merits of any custody dispute. When someone files an appeal with the Nevada Supreme Court, they generally must pay a filing fee or, if they cannot afford it, follow a procedure (under a rule called NRAP 24) to ask the court to waive the fee because of financial hardship. In this case, the appellant, Ryan Michael Jensen, filed his appeal but did not pay the filing fee. The court sent him a notice the same day his appeal was docketed, telling him he had 14 days either to pay the fee or to follow the waiver procedure, and warning him that if he did neither, the appeal would be thrown out. According to the court, Jensen did not pay the fee and did not respond to the notice. The court therefore dismissed the appeal. Because the dismissal is procedural, the court did not consider any of the underlying child custody issues between Jensen and Devyn Nicol Pledger.

A father, representing himself, tried to appeal a Clark County family court ruling about child custody. To move an appeal forward in the Nevada Supreme Court, the appealing party has to file certain paperwork on a schedule - including a "docketing statement" (a basic information form about the case) and, in child custody appeals, a "fast track statement" (a streamlined brief explaining the issues). The appellant also has to deal with trial transcripts: either order them, pay the deposit, or tell the court he does not need them. The Supreme Court gave Merkerson extra time to file these documents in August 2024. In September 2024, it issued another order telling him what to do about transcripts and reminding him of the October 10, 2024, fast track statement deadline. When he missed those deadlines, the court issued a third order in October 2024 giving him 14 more days and warning him that the appeal could be dismissed if he did not comply. Merkerson did not file the required documents and did not communicate with the court. Concluding that he had abandoned the appeal, the Supreme Court dismissed it. The dismissal does not address the merits of the underlying custody decree; it ends this appeal because the appellant did not pursue it.

Karyl Clarke and Tanesha White were never married but have a daughter, T.C., born in 2016. After a tumultuous relationship, they separated in April 2020 following an incident on April 28, 2020, in which Clarke allegedly held a butcher knife to White's neck, choked her, took her phone to stop her from calling for help, blocked her from leaving her apartment, and eventually drove off with the apartment keys, leaving White and the child locked outside late at night. The child was wearing only a shirt and underwear. White obtained a temporary protection order (a TPO — a short-term court order meant to protect someone from harm), which gave her temporary custody. A hearing master found that although he did not believe White's specific knife claim, an act or threat of domestic violence had occurred, or that Clarke posed a credible threat, and extended the TPO for six months. White then moved to Ohio with the child. The TPO was later dissolved when White missed a hearing. Meanwhile, Clarke filed a custody complaint but could not find White to serve her, so he served her by publication (giving notice through a public notice rather than in person). When White did not appear, the court entered a default against her, and about a year later entered a default custody decree giving Clarke sole legal and physical custody. In that decree — issued without hearing anything from White — the court found White's domestic violence allegations false. The court also ordered White to produce the child or allowed Clarke to pick the child up with law enforcement. White moved back to Nevada in 2021, and she and Clarke reconnected. Clarke did not actually get physical custody until March 31, 2022, when he picked up T.C. with police help and took her to Ohio. He did not notify the court that he had done so. The day after Clarke took the child, White appeared in the custody case for the first time and asked the court to set aside (undo) the default decree, saying she had not known about the case. The court held hearings, ordered the child returned to White, and set aside the default decree, explaining that resolving custody on the merits — with both parents heard — was in the child's best interest. After an evidentiary hearing, the court issued an amended decree awarding White primary physical custody. The court found White had committed an "act of abduction" by disappearing with the child for about 22 months, which triggered a legal presumption against giving her custody. But the court found White overcame (rebutted) that presumption because she showed by clear and convincing evidence that she left to protect herself and the child from Clarke's domestic violence. The court found White's testimony about the knife incident credible and did not believe Clarke's denial. Clarke appealed. The Court of Appeals affirmed. It held the district court did not abuse its discretion in setting aside the default decree, because the "catch-all" provision of the rule governing relief from judgments allows relief in extraordinary circumstances, and the need to hear from both parents to determine a child's best interest qualified here. The court also rejected Clarke's argument that setting aside the default was the same as "modifying" custody — once the default was set aside, there was no custody award left to modify. Finally, the court held the domestic violence finding was supported by clear and convincing evidence, and that even if the trial court had wrongly cited a criminal statute to explain how White rebutted the abduction presumption, any error was harmless because the court had independent authority and substantial evidence to reach the same result.

This case is about a long-running custody dispute between two parents of two children. Petriuc and Matas married in November 2012 and had two children. In August 2014, Matas filed for divorce and custody, and the following month the district court entered a divorce decree and custody order by default, finding that Petriuc had been served but did not file an answer. (Petriuc later disputed that he was served.) That initial order gave Matas sole legal custody and primary physical custody, with limited parenting time for Petriuc. After the decree, Matas moved with the children to Arizona without Petriuc's knowledge or court permission, living with her parents. In 2018, again without Petriuc's knowledge, she started guardianship proceedings in Arizona, and her parents became the children's legal guardians. Matas did not contact Petriuc until June 2019, when she told him she and the children were in Arizona. Petriuc visited three times between September and October 2019, after which Matas cut off communication and refused further parenting time. In December 2020, Petriuc filed his first motion to modify custody, pointing to Matas's alleged "instability," her interference with his visits, and her relocation of the children to Arizona without his consent. In April 2022, the district court granted that motion, finding a substantial change in circumstances. The court awarded joint legal custody but let Matas keep primary physical custody, concluding it was not in the children's best interests to uproot them from Arizona to move to Las Vegas. The court significantly expanded Petriuc's parenting time (including summers) and said that if Petriuc later presented additional evidence about Matas's fitness or the children's best interests, the court was "inclined to consider a further modification to joint physical custody." In July 2023, Petriuc filed a second motion to modify custody, arguing the children should relocate to Las Vegas. He attached documents proving the Arizona guardianship existed and said he had successfully reunified with the children. Matas opposed and filed a countermotion asking for four weeks of parenting time over the children's summer breaks. Petriuc did not oppose her countermotion. About a month before the hearing, Matas and her parents agreed to dissolve the Arizona guardianship, restoring her parental rights. After a March 2024 evidentiary hearing, the district court denied Petriuc's motion and granted Matas's countermotion. The court found Petriuc had not shown a substantial change in circumstances since the April 2022 order. It treated the guardianship issue as moot because the guardianship had been dissolved, and it noted that Petriuc could have obtained his new guardianship documents earlier with reasonable diligence. The court found the children were "thriving socially, academically, and developmentally in Arizona" and that uprooting them was not in their best interest. It also granted Matas four weeks of summer parenting time. On appeal, the Court of Appeals affirmed. The court's central reason was that Petriuc did not make developed ("cogent") legal arguments explaining how the district court abused its discretion. He did not challenge key findings—such as the mootness of the guardianship issue or the finding that his reunification with the children was not a substantial change—and he did not engage with the court's best-interest analysis. Because these arguments were not properly raised or developed, the appellate court declined to consider them and left the district court's rulings in place.

Joseph Moss tried to appeal a Clark County family court ruling that involved both registering an out-of-state judgment in Nevada (called "domesticating" a foreign judgment) and child custody. The Nevada Supreme Court reviewed the paperwork and noticed a problem: the order Moss was appealing was only a temporary custody change, and the family court had scheduled an evidentiary hearing for May 2025 to take more evidence and revisit the custody question. The order also did not resolve the domestication issue. The Supreme Court asked Moss to explain why the appeal should not be thrown out for lack of jurisdiction - meaning the court's legal authority to hear the case. Moss argued that the district court "has treated the matter as a final judgment." The Supreme Court rejected that argument, pointing out that the district court had scheduled a future hearing precisely because the custody decision was not final. Because Nevada appellate courts can only hear appeals that a statute or court rule specifically authorizes, and no statute or rule allows an appeal from a temporary custody order, the Supreme Court dismissed the appeal. The court also denied Moss's request to treat the appeal as a petition for a writ of mandamus (a separate kind of court order) but noted he may file such a petition under the appellate rules if he chooses.

This case involves a custody dispute between two parents, Jennifer Crosier and Garrett Crosier, who married in Utah and had three children. After separating in 2017, Jennifer moved to Nevada with the children and Garrett moved to Colorado. Although they divorced in Utah in 2019, the parties agree that no Utah court ever issued a final custody decree. In April 2022, Jennifer filed a complaint in Nevada asking for sole legal and sole physical custody of all three children. In her complaint, Jennifer raised concerns about Garrett's alleged domestic violence, stating that he had a prior child abuse/neglect conviction from Utah and that the children were afraid of him. The two older children were interviewed by the Family Mediation Center (FMC) and described instances of alleged physical abuse by Garrett - one child said he slapped her and caused her to hit her head, and that he kicked the other child with a steel-toed boot; the other child said he picked her up and pulled her by her hair. Both older children said they preferred to stay with Jennifer in Nevada. At a single-day hearing in May 2023, both parents represented themselves without lawyers. The judge told the parties he would "take control of the questioning" to avoid wasting time, and the court itself questioned the parties and witnesses. The court admitted the FMC child interview report into evidence, but it never asked any questions about the abuse allegations in that report or the domestic violence claims from Jennifer's complaint. When Jennifer tried to raise the abuse issue in her closing argument, the court did not allow her to continue, stating she had offered "zero evidence" that Garrett abused the children. At the end of the hearing, the judge said he had to consider "certain factors in evaluating what is in a child's best interest," but he addressed only two of the twelve factors that Nevada law requires. The court decided the parents would share joint legal custody, that Jennifer would have primary physical custody of the two older children, and that Garrett would have primary physical custody of the youngest child in Colorado. The written custody decree that followed did not mention any of the twelve best interest factors and contained no factual findings about the children's best interest. A later post-decree order also failed to address those factors. The Court of Appeals reversed. It explained that when deciding custody, a court's only consideration is the best interest of the child, and the court must consider all twelve factors listed in the statute and put its findings in a written order that ties those findings to the custody decision. Because the decree here contained no such findings, the court found this was an abuse of discretion and reversible error. The court also held that the trial court should have addressed the domestic violence allegations - the FMC report containing those allegations was in evidence, yet the court never determined whether domestic violence occurred. Finally, the court held the trial judge should have analyzed whether moving the youngest child to Colorado was in that child's best interest, using a five-factor test from prior Nevada case law. The case was sent back for a new evidentiary hearing.

Dory and Eli Mizrachi divorced in 2012. In their divorce, the court gave both parents joint legal custody (shared authority over major decisions) and joint physical custody (roughly shared parenting time) of their son, J.M., who was born in 2008. In 2020, Eli asked the court to change the custody arrangement so he would have primary physical custody. He said J.M. reported that Dory had physically struck him, used inappropriate language, and had inappropriate conversations with him, and that Dory sometimes left the home at night, leaving J.M. unsupervised. Eli argued this amounted to a "substantial change in circumstances" affecting J.M.'s welfare and that giving him primary physical custody was in J.M.'s best interest. Dory disagreed, denied mistreating J.M., raised claims of domestic violence she said Eli committed during the marriage, and asked to keep the existing shared arrangement. The case moved through several stages. In March 2022, the court entered an order reflecting a temporary agreement letting J.M., who was older by then, use some discretion about how long he stayed with each parent. Later, the judge originally handling the case, Judge Mary Perry, recused herself (stepped aside) after acknowledging she had improperly asked Dory's attorney to help her courtroom clerk with a court issue. Eli asked her to recuse; Dory did not object. The case was reassigned to Judge Dawn Throne, who reviewed the record and video recordings of prior testimony rather than starting the whole hearing over. Neither party wanted to recall witnesses. After hearing evidence, including testimony from J.M. and both parents, Judge Throne found there had been a substantial change in circumstances, chiefly the serious deterioration of the relationship between J.M. and Dory. The court reviewed the statutory "best interest" factors and concluded it was in J.M.'s best interest to give Eli primary physical custody, while keeping joint legal custody and giving Dory scheduled parenting time. On appeal, Dory made six arguments. The Court of Appeals rejected all of them. It held: the March 2022 order was temporary, not final, so the court could keep holding hearings; Dory waived her complaint about Judge Perry's recusal because she did not object at the time; Judge Throne was sufficiently familiar with the record and did not have to restart the hearing; the custody modification was supported by substantial evidence and was not an abuse of the court's discretion; even if the court was wrong to exclude testimony about pre-divorce domestic violence, Dory did not show that error affected the outcome (so it was "harmless"); and the exclusion of the child's new therapist's testimony was proper under the "law-of-the-case doctrine" because a prior judge had already decided that issue and Dory did not show a reason to revisit it.

Antonecia Moore and Christopher Moten have three children together. Under a partial parenting agreement and a custody order signed in June 2022, the two shared joint legal and physical custody of the children. After an incident at the children's school, Moore was arrested for domestic violence against Moten. Moten then asked the court to hold Moore in contempt for violating the parenting agreement, and Moore filed her own request to hold Moten in contempt. In his response, Moten also asked the court to give him primary physical custody, arguing that the domestic violence and Moore's withholding of the children amounted to a "substantial change in circumstances" - a legal threshold that must be met before a court will reconsider an existing custody arrangement. The district court denied both contempt requests and set an evidentiary hearing (a hearing where each side presents testimony and evidence) on whether to change custody. At that hearing, both parents represented themselves without lawyers. Neither side had properly prepared or exchanged exhibits ahead of time, so the court used documents each side had already filed with their earlier motions. Neither parent objected to the court using those earlier documents. Moore did object to one item - a video of the alleged domestic violence at the school - saying it was tied to her pending criminal case. The court reviewed the video after confirming Moore had earlier received a copy by email. The district court issued a thirty-page order giving Moten primary physical custody. It found that Moten had shown a "substantial change in circumstances affecting the welfare of the children" based on Moore's withholding the children and her act of domestic violence committed in front of them. Analyzing the best-interest factors, the court found clear and convincing evidence that Moore committed domestic violence, that the parents could not co-parent, and that Moore was less likely to support the children's relationship with their siblings. On appeal, Moore raised two main complaints. First, she said the court improperly considered evidence that had not been properly disclosed and relied on hearsay (out-of-court statements). Second, she said that because the judge led the questioning at the hearing, she was denied her right to confront and cross-examine witnesses, which she framed as a constitutional violation. The appeals court rejected both arguments. On the evidence issue, the court explained that Moore did not object at the hearing to most of the evidence or the alleged hearsay, so she gave up (waived) the right to raise those complaints on appeal. As for the video - the one item she did object to - her objection at the hearing was that it related to her criminal case, but on appeal she argued something different: that it was improperly disclosed under a court rule. Because a party cannot switch to a new argument on appeal, the court would not consider it. On the confrontation and due process argument, the court held that the Confrontation Clause - part of the Sixth Amendment to the U.S. Constitution - applies only to criminal prosecutions, not civil proceedings like this custody case. The court also noted that Moore never argued she lacked adequate notice of the hearing, never tried to cross-examine Moten, and never objected to how the hearing was run, so those points were waived as well. The court therefore affirmed the custody decision.

This is a custody dispute between two parents, Nereida Cobian and Armando Emmanuel Ramirez, who had a child, L.R., born in Utah in October 2015. Early on, the parents submitted a letter to a Utah court in which Ramirez appeared to give up his parental rights, but the court did not treat it as a full waiver. Instead, the Utah court gave Cobian sole legal and physical custody and gave Ramirez standard parenting time, and it required Ramirez to pay child support. Cobian moved with the child, first to California and later to Las Vegas. Ramirez, who worked for and then as a civilian contractor connected to the Air Force, moved to Las Vegas as well. Over time, conflict grew. According to the district court's findings, Cobian repeatedly restricted Ramirez's time with L.R., moved to California in June 2021 without Ramirez's consent or a court order, and reported Ramirez to California child-welfare authorities for physical and sexual abuse. That investigation ended with the allegations found "unsubstantiated or inconclusive." California, which had briefly taken emergency jurisdiction, gave jurisdiction back to Nevada in July 2022. Ramirez asked the Nevada court to register the Utah order and to change custody. After an evidentiary hearing that was rescheduled four times, the district court awarded Ramirez primary physical custody, gave the parents joint legal custody, ordered L.R. returned to Las Vegas and enrolled in a Las Vegas school for the spring semester, ended Ramirez's child-support obligation, and held Cobian in contempt (with a $500 fine) for blocking Ramirez's parenting time over Thanksgiving 2023. Cobian appealed. On review, the Court of Appeals rejected each of her arguments. It concluded that Nevada was the child's "home state" and that the district court properly had jurisdiction to register the Utah order and decide custody. It found no abuse of discretion in the district court's decision to keep the case in Nevada rather than transfer it to California, because Ramirez still lived in Nevada and the Nevada court was familiar with the case. It upheld the custody change, noting that the trial judge made detailed findings that circumstances had substantially changed and that the child's best interests favored Ramirez. The appellate court explained that it does not re-weigh evidence or second-guess a trial court's credibility findings, including the trial court's determination that Cobian's abuse allegations were not credible. It upheld the relocation order, the contempt finding, and it declined to order the case reassigned to a different judge, finding that Cobian had not shown bias. The court did not decide certain issues. It declined to address the child-support challenge in detail because that challenge depended on reversing the custody award, which the court affirmed. It found the school-enrollment issue moot because the order concerned only the 2024 spring semester. And it concluded it lacked jurisdiction over the attorney-fees issue because the order under appeal only found that Ramirez was "entitled to" fees rather than actually awarding them.

This case involves a former married couple and their child. Alaa, a Syrian citizen, and Susan Swensen, a U.S. citizen, married in 2013 in the United Arab Emirates (UAE) and had a child there in 2014. In 2017 Susan and the child moved to the United States, settling in Nevada in July 2019. Alaa stayed in the UAE. According to the opinion, the parties kept in touch amicably through Facebook, email, and video calls. In May 2020, Susan started divorce and custody proceedings in Nevada, asking for joint legal custody, primary physical custody, and a change to the child's last name. Alaa was served with the papers but chose not to participate. He instead told Susan that he was not subject to U.S. law and that UAE law should apply. Because he did not respond, Susan obtained a clerk's default, and in March 2021 the court entered a default divorce decree granting joint legal custody, giving Susan primary physical custody, and approving the name change. No appeal was filed from that decree. More than two and a half years later, in October 2023, Alaa filed a motion asking the court to undo the divorce decree, return the child to the UAE for a custody decision, and restore the child's birth name. He said he had tried to begin divorce proceedings in the UAE in April 2020 but could not because he lacked the child's birth certificate and related documents. He said a UAE court issued its own default divorce decree in August 2020 but declined to decide custody, and that this UAE decree was never shown to the Nevada court before it entered its decree. He argued Susan had unlawfully removed the child from the UAE. Susan opposed the motion and asked for an abduction prevention order. She argued the motion was too late under the rule governing motions to set aside judgments, that Nevada was the child's home state, that their communications contradicted the abduction claim, and that Alaa had not shown reversing the name change was in the child's best interest. The district court denied Alaa's motion. It found no factual or legal basis to set aside the decree, noting the parties had communicated extensively after Susan left the UAE and that the child had lived in Nevada for more than six months before Susan filed for divorce. The court found Nevada was the child's "home state" and the United States the child's "home country," giving it authority (jurisdiction) over the case. It also noted Alaa could have participated in the Nevada proceedings but declined to, and had not requested parenting time. On appeal, the Court of Appeals affirmed. It concluded the district court properly had authority over the custody dispute because Nevada was the child's home state and no competing custody proceeding existed in the UAE when Susan filed in Nevada. The court also rejected the abduction argument, pointing to the parties' friendly communications in the record. Finally, the court declined to consider several of Alaa's other arguments because he had either not raised them properly in the lower court or had raised them too late.

This is a short procedural order, not a decision on the merits of the underlying child custody dispute between Alea Rachel Kennedy and Brian Richard Kennedy. When someone files an appeal with the Nevada Supreme Court, they generally must pay a filing fee or, if they cannot afford it, ask the court for permission to proceed without paying (called proceeding "in forma pauperis"). The court told Ms. Kennedy on September 6, 2024, that she had 21 days to do one or the other, and warned her that if she did neither, her appeal would be thrown out. According to the order, she did neither. She did not pay the $250 fee and did not file a motion asking to be excused from paying. She also did not otherwise respond to the court's order. Because of that, the court dismissed the appeal. The order does not address the substance of the custody dispute.

Melinda and Paul Miller divorced in 2016 and share joint physical and joint legal custody of one child. For years, their parenting-time schedule kept changing because of Paul's work as a pilot, and the constant changes led to a lot of litigation. In August 2022, Melinda asked the court to set a permanent schedule. While the case was pending, the court temporarily put in place a week-on/week-off arrangement. In early 2023, Paul asked the court to hold Melinda in contempt - a finding that a person disobeyed a clear court order - because, he said, the divorce decree gave him parenting time on President's Day weekend in odd-numbered years, but Melinda picked the child up from school and took him to a soccer tournament in Utah that weekend without Paul's consent. Melinda responded that Paul knew about the tournament and that his own failure to reliably use his parenting time should excuse her actions. Shortly before the evidentiary hearing, Melinda for the first time asked the court - in her pretrial memorandum - to give her primary physical custody, not just a new schedule. Paul filed his own pretrial memorandum the same day and did not address that request. At the start of the hearing, the court told Melinda it would not consider the primary-custody request because it was raised too late and Paul had not received adequate notice or a chance to defend against it. Melinda's attorney asked to amend the pleadings to match the evidence, but the court declined. After the hearing, the court set a new, more predictable schedule and found Melinda in contempt, concluding she intentionally took the child during Paul's clearly defined parenting time without his written consent. It ordered her to pay a $500 sanction and later awarded Paul $1,800 in attorney fees and costs for the contempt issue. Melinda asked the court to reconsider. In a later ruling, the court found a separate contempt motion by Paul to be frivolous and awarded Melinda $500 in fees for opposing it, reducing what she owed Paul to $1,300 plus the $500 sanction. The court kept the contempt finding and fee award but removed the "floating days" from the schedule. On appeal, the Court of Appeals affirmed on all three points. It held the district court acted within its discretion in finding Melinda in contempt because there was a clear order (the divorce decree), Melinda had notice and the ability to comply, and she intentionally violated it - something she acknowledged in her testimony. The court was not persuaded that Paul's own conduct excused her violation. On the sanction and fees, the court found Melinda's arguments unsupported by relevant authority. On the custody request, the court held the district court properly refused to consider a change to primary custody raised for the first time just before the hearing, because letting it proceed without giving Paul adequate notice and time to prepare would not satisfy due process. The appellate court also noted the district court did not permanently bar Melinda from seeking a custody modification in the future - it simply declined to address it at that hearing.

Wendy Rowland and Barry Yzaguirre share one minor child. According to the opinion, the child was born in Alabama, where Yzaguirre sought to establish paternity, but Rowland took the child to New Zealand and Yzaguirre lost contact. Rowland later moved with the child to Nevada, where she was arrested and convicted of an offense of child abuse and neglect involving the child. Child Protective Services took custody of the child, contacted Yzaguirre, and later returned the child to Rowland's care. Rowland then filed a petition in Nevada asking for sole legal and physical custody. After an evidentiary hearing (a hearing where the parties present testimony and other evidence), the district court found that Rowland had committed an act of domestic violence against the child and had repeatedly frustrated Yzaguirre's relationship with the child, including abducting the child after the Alabama custody proceedings began. The court awarded Yzaguirre sole legal and primary physical custody, allowed the child to relocate to Illinois to live with him, and gave Rowland weekly supervised remote parenting time plus calls on major holidays. A few months later, Rowland filed several motions asking the court to change its custody decisions - she wanted more supervised parenting time, more contact between the child and her half-siblings in Nevada, joint legal custody so she could contact the child's school and medical providers, and an order holding Yzaguirre in contempt for not allowing a phone call on President's Day. After another evidentiary hearing at which both parents testified, the district court denied her requests, finding she had not shown that a substantial change in circumstances justified modifying the custody arrangement, and declined to hold Yzaguirre in contempt, explaining that President's Day was not a major holiday. The court did, however, direct Yzaguirre to give Rowland weekly updates about the child, including documents from teachers, doctors, and other care providers. On appeal, the Nevada Court of Appeals reached four conclusions. First, it dismissed Rowland's attempt to challenge the original October 2023 custody decree because she did not appeal within the 30-day deadline, which means the appellate court had no jurisdiction (legal authority) to review that order. Second, it found no abuse of discretion in the denial of her requests to modify legal custody and parenting time, because a parent seeking to change custody must show a substantial change in circumstances affecting the child's welfare - and Rowland instead essentially re-argued the earlier custody decision. Third, it rejected her due process argument, because the district court gave both parties advance, specific notice of the evidentiary hearing and both attended and presented evidence. Fourth, it rejected her claim that the judge was biased, because she did not show the judge relied on information from outside the case or displayed the kind of deep-seated favoritism or antagonism that would make fair judgment impossible.

After her divorce, Amy Dziedzic continued to litigate custody issues with Michael Dziedzic in the family court in Clark County. She tried to appeal five different orders the family court issued between late 2022 and mid-2024. The Nevada Supreme Court dismissed her appeal because it concluded it did not have authority (jurisdiction) to hear any of the five orders. The court gave three reasons. First, the November 29, 2022, order was only a temporary order, and the Supreme Court had already told her in an earlier appeal (Docket No. 86131) that temporary custody orders cannot be appealed. Second, two of the orders - from March 15, 2024, and April 5, 2024 - were appealed too late. Nevada's appellate rules give a party 30 days to file a notice of appeal after being served with written notice that the order was entered. She was served in March and April 2024 but did not file her notice of appeal until July 8, 2024, well past the deadline. Third, the May 20, 2024, order simply denied reconsideration of earlier orders and enforced them; it did not change custody or otherwise affect rights growing out of the divorce decree, so it was not the kind of order Nevada law allows a party to appeal. The court also addressed several side motions. It granted her requests to file a late docketing statement and to waive the attachment requirement, and denied as moot her request to file an amended docketing statement for typo corrections. It denied as untimely her motion to disqualify Justice Bell, finding she had waived the objection. It took no action on her transcript request and denied as moot her motion to stay various district court orders.

This is a very short procedural order, not a ruling on the merits of the underlying child custody dispute. When someone files an appeal in Nevada, the rules require them to serve (formally deliver) a copy of the notice of appeal on the other parties and to file paperwork showing they did so. Kristopher Gonzalez filed a notice of appeal on August 29, 2024, but did not include that proof-of-service paperwork. The Supreme Court Clerk sent him a notice the same day telling him he had 14 days to fix the problem and warning that, if he did not, the appeal could be dismissed. He did not file the missing proof of service. Because of that, the court dismissed the appeal. The order does not address any of the underlying child custody issues between Gonzalez and Cera Rom.

Edgar Tavares asked the Nevada Supreme Court to step in and cancel a lower-court order that changed a child custody arrangement. He did so by asking for an "extraordinary writ" - either a writ of mandamus (a court order forcing a lower court to do something it is legally required to do) or a writ of prohibition (a court order stopping a lower court from doing something beyond its authority). These writs are not the normal way to challenge a trial-court ruling; they are reserved for unusual situations. The Supreme Court declined to get involved. The court explained that this kind of extraordinary relief is generally available only when the person asking has no other adequate way to challenge the lower-court ruling - and in most cases, a regular appeal is enough. Because Edgar Tavares did not show that he could not simply appeal the custody order through the ordinary appeal process, the court denied his petition without addressing the merits of the custody dispute.

Jeremy and Kelly Herrmann married in 2007 and had two children. In December 2021, Kelly filed for divorce in Nevada, seeking sole legal and primary physical custody. By then Kelly had already moved back to California, while Jeremy still lived in Nevada. In April 2022, the district court entered a default divorce decree that gave Kelly sole legal and primary physical custody and stated that it was in the children's best interests to relocate to California with Kelly. Over the next year, both parents moved out of Nevada. Jeremy filed a change of address in July 2022 indicating a move from Reno to Montana. Kelly filed a change of address in July 2023 indicating a move from California to Pennsylvania. Shortly after Kelly's move, in August 2023, Jeremy filed a motion asking the court to enforce the divorce decree and/or to hold Kelly in contempt, alleging she had relocated the children to Pennsylvania without first getting permission or his consent. At a February 2024 hearing, Jeremy testified he was then in Arizona but not residing there, describing himself as a "fulltime traveler," said he was homeless, and confirmed his address on file was in Montana. Kelly testified she was in Pennsylvania with the children. After the hearing, Kelly filed a custody-modification petition in Pennsylvania, Jeremy filed one in Nevada, and Kelly asked the Nevada court to give up (relinquish) jurisdiction because everyone had left Nevada and proceedings were underway in Pennsylvania. Jeremy asked the Nevada court to hold a conference with the Pennsylvania court to resolve which state should handle the case. The Nevada district court then ruled. On the contempt issue, it found that although Kelly had relocated without seeking the court's permission, Jeremy had not filed the sworn statement (a fact-specific affidavit or declaration) required to support a contempt motion, so the court lacked jurisdiction to find contempt. On the larger jurisdictional question, the court found that once the parents and children no longer lived in Nevada, Nevada lost its "exclusive, continuing jurisdiction" over the custody dispute. After an informal conference with the Pennsylvania court, the two courts agreed Pennsylvania would take jurisdiction, so the Nevada court relinquished the case and denied Jeremy's Nevada custody-modification motion as moot. The Court of Appeals affirmed. It explained that under the law governing which state handles interstate custody cases, Nevada's continuing authority ends when the child, the parents, and anyone acting as a parent no longer live in Nevada. Because nobody disputed that all of them had left Nevada — and had been gone for more than a year before Jeremy filed his August 2023 motion — Nevada had lost that continuing authority. The court noted that Jeremy's complaint about the original decree letting the children move to California could not be reviewed now because he never appealed that decree in time. The court also said Jeremy failed to explain how Kelly's allegedly improper move to Pennsylvania would give Nevada authority to keep handling the case, and he did not point to the relevant statute or any supporting authority. Finally, the court found nothing in the record supporting Jeremy's claim that the district court was corrupt.

Michael Schaefer and Robyn White were never married but share one child, M.S., who is about six years old. For most of the child's life, the two parents shared parenting without a court order, and the child lived mainly with White. According to the opinion, this was due in part to Schaefer working in North Dakota for about nine months in 2018 and to his struggles with substance abuse in 2019 and 2020. By 2022, Schaefer mostly saw the child on weekends. After tensions grew between Schaefer and White's new boyfriend, Schaefer filed a custody complaint in March 2023 and eventually asked for sole legal and sole physical custody. White answered and asked for the same for herself. In June 2023, the district court issued a temporary order giving each parent joint legal and joint physical custody on a week-on/week-off basis, and — because the child was about to start kindergarten — temporarily ordered that the child attend the public school in Schaefer's neighborhood, Roger M. Bryan Elementary School. The court told the parties this temporary school choice was essentially a "coin flip" that would be revisited at trial. After an evidentiary hearing in November 2023, the district court entered a final custody decree. It gave the parents joint legal and joint physical custody but structured the parenting time so that Schaefer generally had the child from Friday after school until Monday morning, while White had the child during the school week (with White also having the second weekend of each school month). The court ordered that the child attend the school in White's neighborhood, Aggie Roberts Elementary School. On child support, the court ordered Schaefer to pay White $1,118 per month and did not require White to pay anything, declining to assign ("impute") income to White because she was seven or eight months pregnant, her prior bartending job was not suitable that late in pregnancy, and the court found she was not unemployed without good cause. Schaefer appealed and raised three main complaints. First, he argued the schedule was not really "joint" physical custody because he had the child for less than 40 percent of the year. The appeals court explained that the 40-percent figure is a guideline, not a strict rule, and that the real question is what is in the child's best interest — a question the district court had analyzed in detail and that Schaefer did not directly challenge. Second, he argued the district court chose the school based only on drive time and logistics rather than the full list of factors Nevada courts use. The appeals court found that the district court had actually made specific findings on each factor, found most of them neutral or inapplicable given that the child was only five and in kindergarten, and that the only meaningful difference the parties presented was the commute. Third, he argued the court wrongly refused to treat White as voluntarily unemployed. The appeals court held that White's late-stage pregnancy provided good cause for not working as a bartender, and that nothing in the order prevents Schaefer from later asking to change child support if circumstances change. The appeals court affirmed the district court's decision on all three points.

Stephanie and Garrett Hatcher were married and have one child together. When Stephanie filed for divorce, both parents asked for joint legal custody, and each wanted to be the parent the child primarily lives with (called "primary physical custody"). In January 2021, the district court granted the divorce and decided the custody arrangement. The court found that Garrett had communicated with Stephanie in an inappropriate manner, so it gave Stephanie primary physical custody and limited Garrett to supervised parenting time on Saturdays and Sundays from 10:00 a.m. to noon. That supervised time was to be run by an agency called Family First Services at Garrett's expense until he could show, through a communications app called Talking Parents, that he could communicate properly with Stephanie. The court also entered a "behavior order" telling both parents not to use abusive or foul language. In 2022, Stephanie asked the court to change the arrangement. She wanted sole legal custody, wanted Garrett's parenting time further restricted because he had attended few of his scheduled visits, and asked the court to hold Garrett in contempt (a finding that a person disobeyed a court order) for using inappropriate language, for claiming the child on his federal taxes, and for leaving the former marital home in poor condition. She also asked the court to make Garrett pay her attorney fees. Garrett opposed her request and filed his own motion asking for unsupervised parenting time. He explained that he had temporarily moved to California for financial reasons and could not visit in person during that period, that he tried to talk to the child by phone but said Stephanie would not help make that happen, and that after returning to Nevada the high cost of supervised sessions limited how often he could see the child. He said he wanted more time, and unsupervised time, to build his relationship with the child. After hearings in August and October 2023, the district court reviewed the parties' testimony and their Talking Parents messages. The court found that the most recent objectionable message from Garrett was in January 2023 and that his communications had been appropriate since then. Because the supervised-time requirement had been put in place due to his poor communication, and because Garrett had shown he could now communicate properly, the court found supervised visits were no longer necessary and posed no safety risk to the child. The court kept Stephanie as the primary physical custodian and kept joint legal custody, but gave Garrett unsupervised parenting time of two days per week, including one overnight. The court did not find Garrett's testimony that money was the only reason he missed visits to be credible, declined to hold him in contempt because he had improved his communication, and denied Stephanie's request for attorney fees. On appeal, the Court of Appeals explained that it does not re-decide the facts or re-weigh whether one witness was more believable than another; instead it checks whether the trial court had solid enough evidence to support its findings and whether it decided for the right legal reasons. Applying that limited review, the court concluded that the trial court's findings were supported by the evidence and that the trial court did not abuse its discretion on any of the four issues Stephanie raised. The court therefore affirmed.

This case is about a mother trying to end a court-ordered guardianship - an arrangement where other adults (here, Clifford C. and Nancy C.) have legal authority to care for her children - so she could regain custody of her three children. The guardianship was put in place in 2016. Amanda agreed to it for her oldest child but objected out loud to it for the two younger children. She then missed a follow-up court date, and the judge established the guardianship over all three children. In 2021, Amanda asked the court to end the guardianship. By then, Nevada had passed a new law, NRS 159A.1915, that took effect in 2017. That law treats parents differently depending on whether they originally consented to the guardianship. Parents who consented only need to show two things: (1) circumstances have materially changed, and (2) they are once again suitable parents. Parents who did not consent must show those two things plus a third, harder thing - that ending the guardianship would "substantially enhance" the child's welfare. The district court treated Amanda as a non-consenting parent for the two younger children. It found she had met the first two requirements but had not shown the children's welfare would be "substantially enhanced" if returned to her. It denied her petition. The Nevada Supreme Court reversed. It held that applying the 2017 statute to a guardianship created in 2016 was an improper retroactive application of the law. When Amanda objected to the guardianship in 2016, the heightened standard for non-consenting parents did not yet exist, so it was not fair to attach that new legal consequence to her past conduct. The Legislature, the court noted, specifically said the new statute applies only to proceedings begun on or after July 1, 2017. The court rejected the argument that earlier Nevada cases (especially Hudson v. Jones from 2006) had already imposed the same standard. Hudson dealt with a different kind of custody situation, and the case it relied on (Murphy v. Murphy) was later overruled by Ellis v. Carucci in 2007. So Amanda was not on notice in 2016 that her objection would trigger the heightened showing later codified in NRS 159A.1915. The court sent the case back to the district court with instructions to evaluate Amanda's petition under the older law - NRS 159.1905(3) (2003) - which asks whether termination is in the best interests of the children. The Supreme Court also affirmed the district court's findings that Amanda had shown a material change in circumstances and was again a suitable parent, leaving only the best-interests analysis for the children to be redone on remand.

Charleslie Wayne Edwards and Benito Santoyo were married in Colorado and have one child together. According to the opinion, the family lived in Colorado for most of the marriage. On December 8, 2023, Edwards filed papers in a Nevada court asking for a divorce and for custody of the child. She claimed that she and the child had been living in Nevada for the previous six months, which she argued made Nevada the right place to handle the divorce and custody dispute. Santoyo asked the Nevada court to throw out the case, arguing it did not have the authority (called "jurisdiction") to hear it. He said he had already started divorce proceedings in Colorado on December 1, 2023. He also said Edwards and the child had only recently arrived in Nevada, and that Edwards had taken the child to Nevada without his knowledge or consent. Under Nevada law, a court cannot grant a divorce unless one of the spouses has lived in Nevada for at least six weeks before the case begins. And under the UCCJEA — a law that decides which state gets to handle child custody — Nevada courts generally can only rule on custody if Nevada is the child's "home state," meaning the child lived here with a parent for at least six months in a row before the case started. The court held an evidentiary hearing to figure out where Edwards and the child actually lived. Edwards testified that she and the child had lived in Nevada since April 2023, but she did not bring documents to back that up. Santoyo testified that Edwards lived with him in Colorado until November 2023. A friend of Edwards, Jesse Leszko, testified that Edwards and the child were at his Colorado home on December 1, 2023, and that Edwards had told him she lived in Colorado at that time. The district court concluded that the evidence showed Edwards had only lived in Nevada since roughly December 1, 2023 — about seven days before she filed her case. Because that did not satisfy the six-week residency requirement for divorce or the six-month "home state" requirement for custody, the court decided it lacked authority over the case and dismissed it, finding Colorado was the more appropriate place for the proceedings. On appeal, the Court of Appeals of the State of Nevada agreed with the district court. It explained that questions about how long someone lived somewhere are factual questions for the trial court to decide, and an appeals court will not re-weigh the evidence or second-guess who the trial judge found believable. Because the district court's finding was supported by adequate evidence, the appellate court affirmed the dismissal.

Michael and Danielle Martin divorced in 2017 and have three children. In an earlier appeal, the Nevada Supreme Court approved the district court's decision to appoint a "parenting coordinator" - a neutral person who helps divorced parents work through disagreements about raising their kids. The district court then issued an order formally appointing the coordinator and setting the terms of that appointment. Michael asked the district court to relieve him from that order; the court refused, and he appealed. The Supreme Court did not reach the merits of Michael's complaints about the appointment. Instead, it concluded that it had no power - no "jurisdiction" - to hear the appeal at all. In Nevada, you can only appeal from the kinds of orders that a statute or court rule specifically allows you to appeal. No statute permits an appeal from an order appointing a parenting coordinator. And the court rule that allows appeals from certain post-judgment orders in custody cases (NRAP 3A(b)(7)) only applies when the order "finally establish[es] or alter[s] the custody of minor children" - which, the court explained, this appointment order did not do. Because the order also did not affect rights coming out of the original divorce decree, no other rule allowed an appeal either. The court therefore dismissed the appeal.

When someone files an appeal in Nevada, the rules require them to show that they delivered a copy of the notice of appeal to the other side. This is called "proof of service." Toni West filed her appeal on June 21, 2024, but did not include this proof of service. The Supreme Court gave her two chances to fix the problem. First, on the same day the appeal was docketed, the court sent a notice telling her she had 14 days to provide the proof of service and warning that failing to do so could result in her appeal being thrown out. When she did not respond, the court issued a formal order on July 16, 2024, again giving her 14 days and again warning her that the appeal could be dismissed. She did not file the required proof of service. Because of that, the court dismissed the appeal without reaching the substance of the underlying child custody dispute.

This is a child-custody case between two parents. The father, representing himself, tried to appeal a decision the family court judge made before the custody question was finally resolved. The judge had ruled that the father made a "prima facie" showing - meaning enough of an initial showing - that changing custody might be in the children's best interest, and the judge sent the parents to mediation on visitation, with a later hearing scheduled if mediation failed. The Nevada Supreme Court did not decide whether the family court was right or wrong about custody. Instead, the Supreme Court concluded that it could not hear the appeal at all, because the order being challenged was not the kind of order Nevada law allows a party to appeal. Under the rule governing appeals in family cases, a party generally can appeal an order that finally establishes or changes custody. This order did neither - it only said there was enough to look further into the question and sent the parents to mediation. Because no statute or court rule permitted an appeal from this kind of interim order, the Supreme Court dismissed the appeal for lack of jurisdiction. The court also denied the father's motion to accept documents and a flash drive, directed the clerk to return those materials unfiled, and took no action on his transcript request given the dismissal.

This is a one-paragraph order from the Nevada Supreme Court closing out an appeal in a child custody case. The person who started the appeal, Nicole Birge, asked the court to dismiss her own appeal voluntarily. The court granted that request and ended the appeal. The order does not describe the underlying custody dispute, the lower court's ruling, or any reasoning. It simply records that the appellant chose not to continue and that the court allowed her to withdraw the appeal under the rule that permits voluntary dismissal.

A mother tried to appeal a family court ruling that denied her request to relocate with her child and her request to have the child produced at a hearing. Before her appeal could move forward, the Nevada Supreme Court spotted a problem with its own ability to hear the case. The problem was timing. After the family court issued the order she wanted to challenge, she filed a motion asking the family court to reconsider. Under Nevada appellate rules, that kind of "tolling motion" pauses the clock for filing an appeal until the family court issues a written order resolving the reconsideration request. She filed her notice of appeal before the family court had entered that written order, which made her appeal premature. The Supreme Court asked her to explain why the appeal should not be dismissed for lack of jurisdiction. She did not respond. The court then issued a second order giving her until June 28, 2024, to respond, and warned that silence could lead to dismissal. She again did not respond. Because the party who brings an appeal carries the burden of showing that the appellate court has jurisdiction, and she made no such showing, the court dismissed the appeal. A dismissal for lack of jurisdiction is not a ruling on whether the relocation denial was right or wrong; it means the appellate court concluded it could not reach the merits at this time.

When someone files an appeal with the Nevada Supreme Court, they generally must pay a filing fee (or, if they cannot afford it, follow a specific procedure to ask the court to waive the fee). In this child custody case, Stephanie Vivas filed an appeal but did not pay the fee when she submitted her paperwork. The court promptly notified her that she had 14 days either to pay the fee or to follow the rule that allows people who cannot afford the fee to proceed without paying it. The notice warned that if she did neither, her appeal would be thrown out. According to the court's order, Vivas did not pay and did not respond. The court therefore dismissed her appeal. The dismissal is procedural - the court did not consider the merits of the underlying child custody dispute.

This case involves three children who had been living under the legal guardianship of their grandmother, Randy Sue K., since 2018. In 2020, the children's mother, Adison R., asked the court to end the guardianship and return the children to her care. After a multi-day evidentiary hearing, the district court agreed and terminated the guardianship. The grandmother appealed, and the children themselves also appealed through their representatives. The grandmother raised several objections. First, she argued that the trial judge applied the wrong legal standard - using a "best interest of the child" analysis from Nevada's child custody statutes rather than the "substantial enhancement" of welfare standard required by Nevada's guardianship statute when a non-consenting parent seeks to end a guardianship. Second, she argued that even under the correct standard, the evidence was not strong enough to justify ending the guardianship. Third, the children's side argued that the court should have appointed a lawyer for them before appointing a guardian ad litem (a person who represents the children's interests in the case). Finally, the grandmother contended that the court did not properly weigh the evidence before deciding the mother was a fit parent entitled to the legal preference parents normally receive. The Nevada Supreme Court rejected all these arguments and affirmed the lower court. The Court explained that the "best interest" factors and the "substantial enhancement" standard, while distinct, involve overlapping considerations - things like a child's physical, developmental, and emotional needs - so it was acceptable for the trial court to discuss best-interest factors as long as it ultimately answered whether the children's welfare would be substantially enhanced by returning them to their mother. The Court found ample evidence supporting that conclusion: the mother was in a better financial position, had a more spacious home, the children's medication needs had not been consistently met under the grandmother's care, and the grandmother had not pursued special-education plans (IEP or 504 plans) for the children's special needs until prompted by the court. Even other adult children of the grandmother testified she was unfit and that the mother could properly care for the children. On the guardian ad litem issue, the Court noted that no one asked for a separate attorney for the children before the close of the evidentiary hearing, so that argument was waived, and in any event the appellants did not show the outcome would have been different. The Court did note that the guardian ad litem's failure to speak with the children was "concerning" but not reversible error. On parental fitness, the Court held that the district court properly considered the relevant factors from the Locklin case - including the mother's absence, her commitment to raising the children, and the impact on their education - and reasonably concluded that the legal presumption favoring placement with a fit parent had not been overcome.

This case involves a parent who tried to appeal a family-court order. The order was an "emergency" temporary ruling that required a child to be returned and gave the other parent temporary sole legal and physical custody. The Nevada Supreme Court did not decide who should have custody of the child. Instead, the court looked at a threshold question: does it even have the power to hear this kind of appeal? The court concluded that it does not. Under Nevada law, the Supreme Court can only hear appeals that a statute or court rule specifically allows. Temporary custody orders - the kind that are not final and remain subject to ongoing review by the family court - are not on the list of orders that can be appealed. Because the court lacked jurisdiction (the legal authority to hear the case), it dismissed the appeal. The parent who filed the appeal will need to pursue any further proceedings about custody in the family court itself, since this order does not resolve the underlying custody dispute one way or the other.

This case involves an appeal from a juvenile court order that placed a child for adoption and put a post-adoption contact agreement into effect. One of the parties, Ericka D., tried to appeal that order to the Nevada Supreme Court. The Clark County Department of Family Services asked the Supreme Court to throw the appeal out, arguing that the Supreme Court does not have authority to hear an appeal from this kind of order. Nobody opposed that request. The Supreme Court agreed and dismissed the appeal. Under Nevada's appellate rules, custody orders that come out of juvenile court proceedings cannot be appealed directly. The court noted that a party who wants to challenge such an order generally must seek writ relief - a different kind of request asking a higher court to step in - rather than filing a regular appeal. Because the appeal was dismissed, the court also relieved respondent Mary H.-L. of an earlier directive to retain new counsel or notify the court that she would not be doing so.

Yvonne Ollerton and Rigoberto Ayala were never married but have two children together, born in 2008 and 2009. In 2016, a court gave the parents joint legal custody and gave Yvonne primary physical custody, meaning the children live mainly with her, while Rigoberto had scheduled parenting time. In December 2022, Yvonne asked the court for permission to move to Ohio with the children in the summer of 2023. She said she wanted to move for her own safety and well-being, describing a history of domestic violence by Rigoberto, including incidents in August 2020 and August 2021 where she said she had to physically defend herself in front of the children. She also said Ohio offered a better education system, a lower cost of living, and cheaper housing, and she attached a cost-of-living and housing comparison between Columbus, Ohio and Las Vegas. She tried to get Rigoberto's written permission by email, but he did not respond. Rigoberto opposed the move, arguing that Yvonne's reasons were personal to her rather than in the children's best interest, and that the children had family support in Las Vegas. However, he acknowledged that the domestic violence occurred, stating "for the domestic [violence] I will hold myself accountable," and at the hearing admitted he was "definitely in the wrong." At a March 2023 hearing, the district court said its job was to decide whether Yvonne had shown "adequate cause" to hold a fuller evidentiary hearing (a hearing where witnesses testify and evidence is presented). The court found she had "sensible good faith reasons" for wanting to move, but was not convinced she had shown that the children would gain an actual advantage from the move or that the move would serve their best interest. The court denied her motion without holding an evidentiary hearing. On appeal, the Court of Appeals of Nevada disagreed with how the district court handled the request. The appeals court explained that when a parent's written filings lay out a prima facie case - meaning enough relevant, non-repetitive facts that, if true, would support the request - the court should hold an evidentiary hearing rather than deny the motion outright. The appeals court concluded that Yvonne's filings did present relevant facts, including the parents' difficulty co-parenting and the financial benefits of moving to Ohio. The appeals court also noted that the district court did not appear to consider the domestic violence incidents - which Rigoberto himself acknowledged - when deciding the motion, and did not explain how relocation would fail to benefit the children given those incidents. For these reasons, the appeals court reversed the district court's order and sent the case back for further proceedings.

This case is about what a parent must prove before a Nevada court can let that parent move out of state with a child over the other parent's objection. Teshome and Jiru were never married but share one young child, A.N.T., born in March 2021. In August 2022, the district court entered an initial custody order giving the parents joint legal and physical custody on a week on/week off schedule. Before that order, Teshome had asked for primary custody so he could move to Georgia, but the court denied that request, finding joint custody was in the child's best interest. After the order was entered, Teshome decided not to move to Georgia because he did not want to give up joint custody, and the parents followed the alternating-week schedule for about seven months. In March 2023, Jiru asked the court to give her primary custody and let her move with A.N.T. to Richmond, Virginia, where she had previously lived and had friends and a godmother, and where she believed she and the child would have a support network and the child could learn about his Ethiopian heritage. After a hearing, the district court granted her request. It found she had a sensible, good-faith reason for the move, that the move was not intended to cut into Teshome's parenting time, that "what is best for [Jiru] is best for [A.N.T.]," and that Jiru's mental health would improve in Virginia. The Court of Appeals reversed. Nevada law (NRS 125C.007(1)) requires a relocating parent to prove three threshold things: a sensible, good-faith reason for the move that is not intended to deprive the other parent of parenting time; that the move serves the child's best interests; and that both the child and the relocating parent will gain an actual advantage from the move. The appellate court agreed that the district court's findings on the first factor - Jiru's good-faith reason - were supported by the evidence. But it held that the district court failed on the other two. On the child's best interests, the district court said only that A.N.T. "will be fine regardless of where he resides" and that what is best for Jiru is best for the child. The Court of Appeals called these "conclusory statements" - broad conclusions without the specific, factor-by-factor findings the law requires. The district court never evaluated the statutory best-interest factors in NRS 125C.0035(4), even though its own earlier custody order had found that Teshome was more likely to foster the child's relationship with Jiru and that "each parent" was bonded with A.N.T. The court also did not weigh evidence that the move could affect Jiru's ability to provide for the child - higher rent, state income tax, no daycare lined up, and a job change from a roasting-plant position paying $21.82 per hour to a barista job with different pay. On the "actual advantage" requirement, the district court found only that Jiru's mental health would improve. It made no findings that the child would benefit, and the Court of Appeals noted that Jiru herself had stated her mental health struggles did not affect her parenting - so her advantage from moving "is not automatically an actual advantage for A.N.T." Because the threshold requirements were not properly analyzed, the appellate court reversed and sent the case back to the district court. It declined Teshome's request to assign the case to a different judge, concluding he had not shown the judge was biased.

Ashley and John Franklin married in 2012 and have two children. Ashley filed for divorce in 2019. At trial, Ashley testified that John had been violent during the marriage, pointing to a 2013 incident that led to a protective order, a 2019 incident in which she said John ruptured one of her breast implants by bear-hugging her, and other conflict in the home. John denied committing domestic violence, though he acknowledged being charged in 2013 and pleading to the lesser offense of disturbing the peace. The district court entered a divorce decree giving the parents joint physical custody. It found that Ashley had not proven domestic violence by "clear and convincing evidence," which is the standard Nevada law requires before a legal presumption against joint physical custody kicks in. The court also ordered John to pay Ashley $300 per month in alimony for 36 months, classified a loan from Ashley's friend Karen Brady for living expenses as community debt, classified a separate loan for Ashley's attorney fees as Ashley's separate debt, and ordered John to pay $3,400 to equalize the property split. After Ashley asked the court to reconsider its domestic-violence findings, the court denied the motion and ordered Ashley to pay John's attorney fees for opposing it, without giving reasons. The Nevada Supreme Court mostly affirmed. On custody, it held the trial judge did not abuse her discretion when she found Ashley's domestic-violence allegations were not proven by clear and convincing evidence, given inconsistencies in Ashley's testimony and the absence of medical records to corroborate the breast-implant injury. The court emphasized that appellate courts do not re-weigh a trial judge's credibility decisions. The court did find one evidentiary error: the trial judge should have admitted a photograph of Ashley's face that Ashley said showed an injury John caused. Ashley's testimony that the photograph fairly and accurately depicted what she claimed was enough to authenticate it. But because Ashley did not include the photograph in the appellate record, the Supreme Court could not tell whether excluding it changed the outcome and treated the error as harmless. The court agreed with the trial judge's exclusion of computer-aided dispatch (CAD) police-call records as hearsay, because no records custodian or other qualified person testified or provided an affidavit. On the rest of the custody analysis, the Supreme Court found the trial judge properly walked through Nevada's twelve "best interest" factors. The judge actually concluded, by a "more likely than not" standard, that some domestic violence had occurred and weighted that factor in Ashley's favor — but a single favorable factor does not require denying joint custody. On finances, the court upheld the trial judge's distribution of bank accounts to John (based on his testimony that the accounts had no funds), the classification of Ashley's attorney-fee loan as her separate debt (because it was incurred after separation and not for community benefit), and the $3,400 equalization payment. The court rejected John's argument that the living-expenses loan should not have been treated as community debt, holding he had waived that argument by not raising it at trial. The court also upheld the alimony award, finding the trial judge had properly considered the statutory factors. The court reversed only on the attorney-fees award. The trial judge had ordered Ashley to pay John's attorney fees for her unsuccessful reconsideration motion without explaining why the motion was unreasonable or harassing. Losing a motion, by itself, is not enough to justify fees under the statute the trial judge invoked. Two justices, Bell and Stiglich, would have gone further. They wrote that the trial judge's own factual findings — including references to two protective orders, a hole punched in a wall, scratches and a bruise observed by police, and a finding that "John would force Ashley into non-consensual sex" — already established domestic violence by clear and convincing evidence and required the trial judge to apply the rebuttable presumption against joint custody. The majority disagreed, reading some of that language as a summary of Ashley's testimony rather than as the court's own findings.

Virginia and James were married in 2014, have three children, and divorced in 2015. At first Virginia had primary physical custody (meaning the children lived mostly with her), and James had limited parenting time. Over the following years, both parents filed many motions about custody. Virginia repeatedly raised allegations that James abused the children, but investigations by the Division of Child and Family Services (DCFS) and, in one instance, the FBI found those allegations unsubstantiated and led to no charges. In July 2022, James asked the court for sole physical custody, arguing that Virginia was harming the children's relationship with him and coaching them to say he abused them. After a one-day hearing in June 2023 — which included the judge privately interviewing two of the children and testimony from the children's therapist and both parents — the district court awarded James what it called "primary physical custody." The court also suspended Virginia's parenting time for three months, then limited her to one supervised visit per month, and required her to undergo a psychological evaluation before any unsupervised time. The Court of Appeals agreed with Virginia on one point: even though the district court labeled its decision "primary physical custody," the practical effect was to give James **sole** physical custody, because Virginia was left with essentially no meaningful in-person time with the children for the foreseeable future. Under Nevada law, before a court can award sole physical custody, it must make specific written findings — separate from its analysis of the children's best interests — either that the other parent is unfit to have the children live with them, or explaining why primary physical custody is not in the children's best interest. The district court did not make those separate findings, so the Court of Appeals reversed that part of the order. On the other issues, the court sided against Virginia. It held she waived (gave up) several arguments by not raising them at the hearing below — including her objections to the judge considering the 30 exhibits attached to James's motion, and her relocation argument. The court found she had a fair hearing and did not show the judge was biased, so it declined to send the case to a different judge. Because Virginia said in her reply brief that she had already completed the psychological evaluation, the court did not address that issue. The case goes back to the district court to enter a new custody order following the guidelines the court set out in a prior case called *Roe v. Roe*.

This is a child-custody appeal that never reached the merits. Shante Harvey asked the trial court to change a custody arrangement for a minor child. The trial judge denied that request, and Harvey - representing herself, without a lawyer - appealed to the Nevada Supreme Court. When you file an appeal in Nevada, you have to submit certain starting paperwork early in the process, including a "docketing statement" and a "fast track statement" (short documents that tell the appellate court what the case is about and what issues will be argued). Harvey did not file those documents on time. She asked the Supreme Court for more time to file them - repeatedly. On March 14, 2024, the court denied her third request for an extension and ordered her to file the documents by April 12, 2024. Instead of filing them, she asked for a fourth extension. On April 29, 2024, the court denied that fourth request, gave her another 14 days, and warned her that if she still did not comply, the appeal could be dismissed. She did not file the documents and did not contact the court again. Because of that, the Supreme Court dismissed the appeal. The order does not address the underlying custody dispute; it ends the appeal on procedural grounds only.

A father, identified in court papers as Clifford Allyn J., tried to appeal a Clark County district court order that placed his child, M.J., into protective custody. Protective custody in this context is governed by a Nevada statutory scheme - NRS Chapter 432B - that addresses the protection of children from abuse or neglect. The Nevada Supreme Court did not reach the merits of the father's challenge. Instead, the court explained that the order he was trying to appeal was only a temporary one: it set up custody for the time being and scheduled further proceedings in the district court. Under Nevada law, an appellate court can generally only review final orders, and temporary custody orders entered under NRS Chapter 432B are not considered final. Because the order was not final, the Supreme Court concluded it had no power - no jurisdiction - to hear the appeal, and it dismissed the case. The court also noted that, given the dismissal, it would not act on a motion the State had filed to dismiss the appeal for missed filing deadlines, and it directed the clerk to file the docketing statement that had been received on June 5, 2024.

Venus Priya Ram and Cleavon Roy Kiran married in 2008 and have two children. In 2020, Kiran filed for divorce and asked the court for sole legal and primary physical custody. Kiran had moved to California but acknowledged Nevada was the children's home state; he asked for primary physical custody so the children could live with him in California. Ram answered and asked for joint legal custody and primary physical custody. While the case was pending, the district court entered a temporary order letting the children stay with Ram in Nevada, with Kiran having parenting time every other weekend. At an evidentiary hearing, both parents testified. Kiran testified about Ram's methamphetamine use, acts of domestic violence, and arrests; about the oldest child's dietary issues (possibly related to Crohn's disease) and mental health issues; and about his own good relationship with the children. Ram testified that the children had always lived with her, that she facilitated their contact with Kiran, that she took the oldest child to therapy, and that she was working toward sobriety, while acknowledging her methamphetamine use, her criminal history, that she was on probation, and that she had failed two drug tests while on probation. Nevada law requires courts deciding custody to focus on the "best interest of the child," using a list of factors set out in statute. The district court's written decree found that six of those factors favored Kiran and none favored Ram, and it awarded Kiran primary physical custody (with joint legal custody to both parents). Ram asked the court to reconsider, arguing among other things that the court had allowed the children to be relocated to California without considering the "relocation factors" and had admitted improper evidence. The court denied reconsideration, explaining in part that it was not required to consider relocation factors because no final custody order existed before the decree, and that neither party had presented evidence about the children's wishes. On appeal, the Court of Appeals rejected each of Ram's arguments. First, it declined to review her complaints about the evidence admitted at the hearing (testimony about her arrests and alleged hearsay) because she never objected at the hearing itself - raising the issue for the first time in a reconsideration motion was too late. Second, it rejected her claim that the judge's questioning showed bias, because Ram did not show the judge relied on information from outside the case or displayed "a deep-seated favoritism or antagonism that would make fair judgment impossible." Third, it held the custody award was not an abuse of discretion: the written findings were supported by substantial evidence, and an appellate court does not reweigh evidence or second-guess credibility calls. Where the judge's oral comments differed from the written decree, the written order controls. As to Ram's complaint that the court should have interviewed the children about their wishes, the appellate court noted that neither party presented such evidence and that Ram never explained what the children would have said or how it would have changed the result. Fourth, even assuming the district court should have considered the relocation factors, any error was harmless because Ram did not show a different result might reasonably have been reached. Finally, Ram's argument that the court needed to find a "substantial change in circumstances" before departing from the temporary order was never raised in the district court, so the appellate court would not consider it for the first time on appeal.

Tiffany and James Sullivan divorced in 2012 and agreed to share joint legal and physical custody of their daughter, G.S. Over the following decade, James filed several motions asking the court to give him primary physical custody. The appeal in this case arises from his third such motion, filed in April 2022. James pointed to three alleged changes: an October 2021 domestic violence incident between Tiffany and her then-boyfriend, Martin (who was later convicted of felony aggravated stalking for violating protective orders Tiffany obtained against him); a February 2022 conversation James recorded with G.S., in which the child said Tiffany often left her alone to care for her younger half-sister, did not prepare her meals, and that she would prefer to live with James; and concerns that G.S. was underweight and possibly not eating properly. Before the trial (called an "evidentiary hearing"), the court ordered that G.S. be interviewed by a neutral professional. The parties settled on Dr. Stephanie Holland, who interviewed the child and sent her report to the court. But Tiffany did not formally list Dr. Holland as a witness until after the deadline the parties had agreed to. On the first day of the hearing, James raised no objection—in fact, he agreed to take witnesses out of order so Dr. Holland could testify the next morning. The next morning, however, James objected that Tiffany had disclosed Dr. Holland too late, and the district court agreed, refusing to let Dr. Holland testify or her report come into evidence. After hearing testimony from Martin, a former babysitter, G.S.'s pediatrician, James, and Tiffany, the district court awarded James primary physical custody, finding that five of the statutory "best interest of the child" factors favored James and none favored Tiffany. The Court of Appeals concluded the district court made mistakes—but not mistakes big enough to change the outcome. First, it held that James waited too long to object to Dr. Holland's testimony. Because he participated in the interview process, knew about the late disclosure a month before the hearing, and even agreed on the first day of the hearing to let Dr. Holland testify out of order, he could not spring the objection at the last minute. The court also emphasized that Nevada public policy strongly favors letting courts consider all evidence bearing on a child's best interest; by excluding the court-appointed interviewer's testimony and report, the district court "hindered its own inquiry into G.S.'s best interest" and, in effect, sanctioned the child for her mother's procedural misstep. Second, the appellate court found that two of the district court's best-interest findings were not backed by substantial evidence: the finding that the parents' "ability to cooperate" factor was neutral (the record showed James was the less cooperative co-parent, including never giving Tiffany the number to G.S.'s phone at his house), and the finding that the "relationship with each parent" factor favored James, which rested on the recorded conversation without the expert analysis Dr. Holland would have provided. Even so, the Court of Appeals affirmed. Under Nevada law, an error justifies reversal only if it likely would have changed the result. Here, the remaining best-interest findings were supported by substantial evidence—particularly that James consistently provided G.S. three meals a day, got her to school on time, and offered a stable home—and Tiffany did not include Dr. Holland's report in the appellate record, which limited the court's ability to assess what difference it might have made. Finally, the court rejected Tiffany's claim of judicial bias: judges are presumed impartial, and rulings formed from what a judge learns during the case itself are not evidence of bias.

Eric and Samantha were never married but have a child together. Eric went to court asking for primary physical custody and child support. After some back-and-forth motions, the court scheduled a calendar call and an evidentiary hearing to decide custody, and notified both parties. Eric did not show up to the calendar call. The court's minutes reflect that the judge said the evidentiary hearing would still happen, and if Eric again failed to appear, the court would strike his complaint and enter a custody order for Samantha. Eric did not appear at the evidentiary hearing. As a result, the court struck his complaint, entered a default against him (a default is a judgment entered against a party who fails to participate), and — after hearing testimony from Samantha in what the court called a "prove-up hearing" — awarded Samantha sole legal and sole physical custody. The decree also said child support would be handled by the district attorney's office and would be retroactive to May 2019. After the decree, Eric filed several motions, including one asking the court to vacate (cancel) the custody decree and one seeking a preliminary injunction. The court denied both, and Eric appealed. On appeal, the Court of Appeals focused on whether the district court properly explained its custody decision. Under Nevada law, when deciding custody, a court's only consideration is what is in the best interest of the child, and it must make specific written findings about that. The Court of Appeals concluded that the district court did not make these required findings — it decided custody based on the default without analyzing or even mentioning the best-interest factors, and without doing the additional analysis Nevada law requires before awarding sole physical custody. Because of this, the appellate court reversed the denial of Eric's motion to vacate and sent the case back for the district court to redo the custody determination with proper findings. The appellate court also reversed the award of attorney fees and costs to Samantha, since that award was tied to the custody decision. The court affirmed one part of the lower court's rulings: the denial of Eric's motion for a preliminary injunction. Eric provided no argument supporting that part of his appeal, so the court did not disturb it. The appellate court also noted that the district court had improperly deferred the child support calculation to the district attorney's office. Under Nevada law, the court itself must determine child support, so on remand it must make that determination. In the meantime, the existing custody arrangement stays in place, subject to change by the district court.

Victor and Judith were married in 1994 and divorced in 2019 under a stipulated decree - a divorce agreement the parties agreed to and the court approved. That decree said the parents shared "joint physical custody" of their children, but the actual weekly schedule gave Victor the children only from Monday morning to Wednesday morning, with Judith having them the rest of the week. Victor twice asked the court to change the schedule to a week-on/week-off arrangement so the parents would split time equally. The district court denied those requests and concluded that the original schedule, though labeled "joint physical custody," really described a primary physical custody arrangement. In an earlier appeal, the Court of Appeals sent the case back (reversed and remanded) because the district court had not evaluated the "best interest of the child" factors set out in state law before changing the custody label. On remand, the district court held an evidentiary hearing and then formally awarded Judith primary physical custody. This time the court went through the best-interest factors listed in NRS 125C.0035(4). It found no history of mental illness, abuse, or domestic violence, but it found the parents had an extensive history of conflict and an inability to co-parent. Among other things, the court pointed to Victor's pattern of interrupting Judith's vacation time with the children - including an incident where Victor followed Judith to Nigeria and accused her of kidnapping the children, which led to Judith being arrested and temporarily detained. The court found Judith more likely to allow the children frequent contact with Victor, better positioned to meet the children's needs, and well equipped to handle their physical, developmental, and emotional needs. Victor then hired a lawyer for the limited purpose of filing a motion to alter or amend the decision. He argued that the court had failed to say whether there was a "substantial change in circumstances" justifying the custody change, and he challenged how the court weighed the witnesses and evidence. The district court denied that motion, explaining that at the hearing the judge had specifically identified what it considered a substantial change in circumstances - the parties' inability to co-parent, Victor's history of not complying with court orders, and his controlling personality. On this appeal, the Court of Appeals affirmed. It gave two main reasons. First, Victor raised the "substantial change in circumstances" argument too late - only in his motion to alter or amend, not before the evidentiary hearing. And because Victor did not provide the appellate court with the transcript of the evidentiary hearing, the court presumed the missing transcript supported the district court's decision. Second, even if the district court should have explained its substantial-change reasoning in the custody order itself, any such error was harmless because the court later spelled out that reasoning in the order denying the motion to alter or amend; read together, the two orders contained all the findings needed to modify custody. The court also rejected Victor's argument that the order lacked evidentiary support, again because the missing transcript prevented review.

This case involves an attempt to appeal a decision made in a juvenile court case about where minor children should be placed. The appellant, Gidget Stevens-Parker, asked the Nevada Supreme Court to review a district court order that denied her motion to have the children placed with her. Before deciding whether the lower court was right or wrong, the Supreme Court has to confirm that it has the legal authority - "jurisdiction" - to hear the appeal at all. Not every district court ruling can be appealed; Nevada's appellate rules list which kinds of orders are appealable. The Supreme Court flagged that orders about child custody that come out of juvenile proceedings are not on the list of appealable orders under NRAP 3A, and asked the appellant to explain why the appeal should be allowed to go forward. In her response, the appellant agreed that the rule she had cited (NRAP 3A) was not the right one and asked the court to switch the appealability code to NRAP 3E. She also argued the appeal should not be dismissed because dismissal would cause her serious harm. The Supreme Court explained that NRAP 3E only governs how child custody appeals are processed and briefed once they are properly before the court - it does not itself create a right to appeal. Because no rule or statute authorizes an appeal from this kind of juvenile-proceeding custody order, and because hardship to a party cannot create jurisdiction where none exists, the court dismissed the appeal. The court also addressed a side point: the appellant suggested that a settlement judge had already decided there was no jurisdictional problem when briefing was reinstated. The court explained that settlement judges do not have the authority to make final jurisdictional determinations, and that the order reinstating briefing came from the court itself and did not analyze jurisdiction.

This case began when a Clark County family court judge granted Juniper Olsen's request to relocate with the parties' minor children. John Olsen appealed that decision to the Nevada Supreme Court. While the appeal was pending, John Olsen's lawyer asked to withdraw from representing him. On January 19, 2024, the Supreme Court allowed the lawyer to withdraw, paused the briefing schedule, and told Olsen to let the court know whether he would hire a new lawyer or represent himself. The court warned him that if he did not respond, his appeal could be dismissed. Olsen did not respond. On March 21, 2024, the court tried again, giving him 14 days to either have a new attorney file a notice of appearance or notify the court in writing that he would proceed on his own. The court repeated its warning that failing to comply could end the appeal. Olsen still did not respond or communicate with the court in any way. Concluding that he had abandoned the appeal, the Supreme Court dismissed it. The result is that the underlying district court order allowing relocation with the children stands, because the appeal challenging it has been terminated without a decision on the merits.

This case concerns which state's courts have the authority to decide who should be appointed guardian of a young child, Y.U.G. The child was born in Las Vegas in June 2022 to Daron G. and Sway Dumes. When the child was about ten months old, the parents concluded they could not care for him because they did not have stable housing, so they entrusted him to his paternal aunt, Ladesha G., who lives in Compton, California. In April 2023, Ladesha took the child to live with her in California, while the parents stayed in Las Vegas. About three months later, in July 2023, Ladesha brought the child back to Las Vegas to obtain his birth certificate and social security card. While there, she filed a petition asking a Nevada court to appoint her as the child's guardian, and the parents consented. After filing, she returned to California with the child. At an October hearing, the district court raised a concern: because the child had been living in California after the petition was filed, the judge questioned whether a Nevada court had the power (called subject matter jurisdiction) to hear the case. The court then issued a written decision denying the petition, concluding it lacked jurisdiction because "California is the home state." The Court of Appeals disagreed and reversed. It explained that Nevada law lets a Nevada court hear a child custody or guardianship matter if Nevada was the child's "home state" within six months before the case was filed, so long as the child is now outside Nevada but a parent still lives in Nevada. Here, the child had lived in Nevada from birth in June 2022 until moving to California in April 2023 — more than ten months — so Nevada was his home state. The guardianship petition was filed in July 2023, only about three months after the child moved, which is within the six-month window. And even though the child was in California when the petition was filed, both parents still lived in Las Vegas. Because all of those conditions were met, the court held that the Nevada district court did have jurisdiction and should not have denied the petition for lack of it. Because that conclusion resolved the appeal, the Court of Appeals sent the case back to the district court to proceed, and did not address the other issues Y.U.G. raised.

Lauren and Taylor Wooten were married and had one child together. On December 31, 2020, Taylor filed for divorce in Nevada and asked for joint legal custody and primary physical custody (the arrangement where a child lives most of the time). Taylor's papers said Lauren had been served with the divorce documents at her Florida home. Lauren did not respond in time, and the court entered a divorce decree giving Taylor primary physical custody. Lauren then asked the court to undo the decree, arguing she had not been properly served because the documents went to a former address. In that same request, she asked for primary physical custody herself, for child support, and said the child had lived with her in Florida since 2019. The court decided to keep the parties divorced but to reopen and decide the disputed custody and support issues on their merits. Because Lauren argued the child's "home state" was Florida, the Nevada court held a conference with a Florida judge to figure out which state should decide custody, as required under a law called the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) - a set of rules that decides which state's courts handle a child custody case. The judges concluded the child had no true "home state" in 2020 because he had not lived in either state for six straight months before the case was filed. Since the Nevada case was filed first and a custody order already existed there, the Florida judge declined to take the case, and Nevada kept jurisdiction. After an evidentiary hearing where both parents testified, the court gave the parties joint legal custody but gave Taylor final say on important educational and urgent medical decisions when the parents could not agree. It also gave Taylor primary physical custody. The court found, among other things, that Lauren had moved to Florida with the child without Taylor's consent, had at times blocked Taylor's communications, and had withheld the child during the holidays, while Taylor was more focused on the child's needs and made sure the child wore his prescription eyeglasses. On money, the court ordered Lauren to pay Taylor $300 per month in child support - a reduced amount, adjusted downward to account for the cost of transporting the child to Florida for Lauren's parenting time and the parties' relative incomes. It also had the parties split extracurricular costs. The court rejected Lauren's later request for about $41,000 in back child support, finding Taylor had credibly testified that he supported the child financially even after the move. The court denied both sides' requests for attorney fees. The Court of Appeals affirmed everything. On service of process, it held Lauren had given up that argument because she asked the court to decide the case on the merits instead of asking it to dismiss. On the other issues, it found the district court's decisions were supported by the evidence and within its discretion, and it noted that an appeals court does not reweigh evidence or second-guess a trial judge's credibility findings.

Amy Gray tried to appeal district court orders that placed her minor children in protective custody under a Nevada statute (NRS Chapter 432B) that governs child welfare proceedings. Before reaching any of her arguments, the Nevada Supreme Court examined whether it had the power - the "jurisdiction" - to hear the appeal at all. The court concluded it did not. The orders Gray challenged were temporary: they set custody on an interim basis and scheduled the case for further proceedings in the lower court. Under prior Nevada Supreme Court precedent, temporary orders in NRS Chapter 432B cases are not considered final decisions, and only final decisions can be appealed at this stage. Because the orders were not appealable, the court dismissed the appeal without addressing the merits. The court also noted that, given the dismissal, it would not act on Gray's pending motion to proceed in forma pauperis (without paying filing fees) or her motion for a stay.

A mother, Amy Gray, tried to appeal a district court order that placed her minor child in protective custody under Nevada's child-welfare statutes (NRS Chapter 432B). The Nevada Supreme Court did not reach the merits of her challenge. Instead, it concluded it had no power to hear the appeal at this stage. The reason is procedural. The order Gray challenged was a temporary one - it set custody on an interim basis and scheduled the case for further proceedings in the district court. Under longstanding Nevada law, only final orders in this type of case can be appealed; temporary orders cannot. Because the order Gray appealed was temporary rather than final, the Supreme Court dismissed the appeal for lack of jurisdiction. The court also declined to act on Gray's request to proceed without paying filing fees, noting that the dismissal made that request moot.

This is a child-custody appeal that the Nevada Supreme Court threw out before reaching the merits. The reason was timing. When a trial court issues a final order, the losing party has a limited window to file a "notice of appeal" - the document that starts the appeal process. In this case, notice that the district court had entered its custody order was mailed to Dollye Moore on January 12, 2023. Under the appellate rules, that meant she had to file her notice of appeal by February 16, 2023. She did not file it until February 29, 2024 - more than a year late. Because the deadline to appeal is jurisdictional, meaning the Supreme Court has no power to hear an appeal filed after the deadline, the court dismissed the case without considering any of the underlying custody arguments.

This is a short procedural order. Mr. Kaloustian tried to appeal a district court ruling in a custody case, but he filed his notice of appeal at the wrong time. After the district court issued the order he wanted to challenge, someone filed a timely motion asking the district court to reconsider that order. Under Nevada appellate rules, certain post-judgment motions like a motion for reconsideration can "toll" - that is, pause - the deadline to appeal until the district court rules on them in a written order. Mr. Kaloustian filed his notice of appeal after the reconsideration motion was filed but before the district court entered a written order resolving it. According to the Supreme Court, that motion was still pending in the district court at the time of this order. Because the appeal was filed too early, the Supreme Court concluded it had no jurisdiction to hear it and dismissed the appeal. The court noted in a footnote that Mr. Kaloustian may file a new notice of appeal once the district court enters a written order finally resolving the motion for reconsideration.