Nevada family-law case summaries

Norma and Raymond Newcomb married in 1993 and divorced in 2020 through a stipulated decree - a divorce agreement the parties negotiated and the court approved. The decree treated their Henderson, Nevada home as community property (property belonging jointly to both spouses), gave Norma some lump-sum alimony plus an extra $15,000 "off the top" when the home sold, and split the remaining sale proceeds evenly. The decree also said Norma would list the home for sale herself (to save on realtor fees) and would move out, after which Raymond would have exclusive possession, with Raymond agreeing to cooperate with listing and showing the home. Things did not go smoothly. Raymond changed the locks on the home in August 2020. Norma said this locked her out and prevented her from preparing and listing the home, and that Raymond would not cooperate with a realtor she tried to bring in. Raymond said Norma had moved out of state and never genuinely tried to sell the home. The home was not sold until 2023, after Raymond went to court. In 2023, Raymond asked the court to find that Norma had violated the decree by not listing the home, and he argued that the resulting delay cost him money in mortgage payments that should be taken out of Norma's share of the sale proceeds. Norma responded that Raymond should be held in contempt and should bear the mortgage payments himself, because he was the one in exclusive possession and had locked her out. After a two-day evidentiary hearing spread over several months, the home sold for roughly $575,000. The district court found that it was not possible for Norma to list the home because she had been locked out, and that requiring her to list it would have been "an act of futility and impossibility." The court also noted that the community actually benefited from the delayed sale, because the home's value rose by about $180,000. Even so, the court ordered - without explaining why or citing any legal authority - that $26,929.37 in mortgage principal be deducted from Norma's share of the proceeds and given to Raymond. The Court of Appeals focused on that unexplained deduction. It observed that although the district court made detailed findings about why Norma could not list the home, it made no findings and gave no legal reasoning for making Norma responsible for the entire mortgage principal amount. The appellate court found this especially notable because the original reason Raymond asked for repayment was Norma's supposed deliberate delay - a delay the district court itself had found was actually impossible because of Raymond's actions. Because the order lacked the findings and legal explanation needed for the appellate court to review it, the Court of Appeals reversed the part of the order dealing with the mortgage principal payments, affirmed everything else in the challenged order, and sent the case back to the district court with instructions to explain the legal basis for its ruling on the mortgage principal payments.

Robert and Joanna Ronchi began dating in 2004. The day before their 2008 wedding in Pennsylvania, they signed a premarital agreement - a contract made before marriage that decides how property will be divided if the couple later divorces. The agreement said it would be governed by Pennsylvania law, listed each person's separate property (including Robert's interest in his business, Element 115, and his retirement accounts), and included provisions in which each spouse gave up any claim to property held in the other spouse's sole name. Joanna, a Polish citizen, was 19 weeks pregnant when she signed. The couple married the next day and moved to Nevada in 2010. In 2015, Robert bought a house, titled only in his name, that became the family home. Joanna filed for divorce in 2022. After hearings, the district court ruled the premarital agreement was valid. It then divided the couple's property, awarding Joanna half of the portion of Robert's Fidelity IRA that came from his wages during the marriage and half of the equity in the house, while confirming Robert's business interest as his separate property. The court later ordered Robert to pay Joanna $30,304 in attorney fees. Both sides appealed. The Nevada Court of Appeals resolved the appeal in four main parts. First, it upheld the ruling that the premarital agreement was valid. Because the agreement chose Pennsylvania law, the court applied Pennsylvania contract principles, under which signed agreements are presumed valid and a person challenging one must prove it invalid by clear and convincing evidence. The district court had found that Joanna generally understood the agreement's purpose, could read and write English at the time, and that both parties handwrote on the agreement, "I choose to waive representation by an attorney." The district court was not persuaded that her pregnancy and immigration status amounted to duress, and the Court of Appeals concluded those findings were supported by substantial evidence. Second, the Court of Appeals reversed the award to Joanna of half of the marriage-era contributions to Robert's Fidelity IRA. Although the agreement never specifically said Robert's wages would be his separate property, its plain language released each spouse's rights to "[a]ny and all rights to any property of the other party titled in the other parties' sole name, whether before or after the marriage." Because the IRA was solely in Robert's name, the court held it remained his separate property even though marital wages went into it. For the same reason, the court reversed the ruling giving Robert a community interest in Joanna's own solely titled Fidelity IRA. Third, on the house, the Court of Appeals held the district court applied the wrong legal framework. The district court had used Nevada's "gift presumption" caselaw - the idea that when a spouse signs over title, she is presumed to have gifted her interest - and found Joanna rebutted that presumption with evidence that the house was titled in Robert's name only because of her credit problems, was paid for from a joint account, and that Robert admitted in an audio recording he had promised to put her name on the house and still "owed" it to her. The appellate court said that under the premarital agreement's plain language, property titled in one spouse's name stayed separate, so the gift-presumption analysis was error. But it concluded the substance of Joanna's argument and the district court's findings pointed to a different doctrine: "constructive fraud" - a breach of the special duty of trust spouses owe each other, which can allow a court to impose a "constructive trust" recognizing that an asset is actually co-owned despite how it is titled, even where a premarital agreement exists. The court vacated the ruling on the house and sent the issue back for the district court to decide whether Joanna established constructive fraud giving rise to a constructive trust. Fourth, the court rejected Joanna's argument that she was entitled to a share of the increase in value of Robert's business, Element 115. The Pennsylvania statute she relied on excludes from marital property anything the parties excluded by valid agreement, and the business was listed as Robert's separate property in the agreement's financial disclosure. Finally, because part of the property division was reversed, the court vacated the $30,304 attorney fee award. The case now returns to the district court for further proceedings consistent with the order.

Salvatore Carrera and Lori Peterson were never married but have one child together, N.P., born in 2012 and identified in the opinion as having autism. Since 2014, the parties shared joint legal custody, with Peterson holding primary physical custody (meaning the child lived mainly with her) and Carrera having parenting time. In 2024, after Carrera sought changes, the parties agreed to keep that arrangement, with Carrera having parenting time in Texas. In March 2025, Carrera again asked the court to change custody. His request centered on an October 2024 incident in which Daniel, Peterson's ex-husband with whom she had reconciled and was living, was arrested for domestic violence against Peterson. Carrera argued that he should get primary physical custody and be allowed to move N.P. to his home in Texas, pointing to domestic violence in Peterson's home, alleged neglect, and instability, and saying his own home was stable and could provide therapy and educational resources for N.P.'s autism. The district court held an evidentiary hearing where Carrera, Peterson, Daniel, Peterson's sister, and three sheriff's deputies testified. The judge found, by a preponderance of the evidence (meaning "more likely than not"), that N.P. had lived in a home where domestic violence occurred, and even found that this factor favored Carrera. But weighing all the relevant factors together, the court concluded that N.P.'s best interest was served by staying with Peterson. The judge emphasized N.P.'s special needs, the value of stability, N.P.'s close relationship with both Peterson and Daniel, and that Daniel had been a consistent parental presence. The court denied Carrera's requests. On appeal, the Court of Appeals affirmed. It explained that a judge's custody decision is reviewed only for "abuse of discretion" - the court will overturn it only if no reasonable judge could have reached the same conclusion. The appeals court rejected each of Carrera's arguments: On the excluded 9-1-1 recordings, the court said Carrera never identified who made the calls, either below or on appeal, so he did not show the trial judge was wrong to exclude them for lack of authentication. On his other evidentiary complaints, the court said he only pointed to transcript page numbers without making a developed argument, so it would not consider them. On the discovery issue, Carrera argued that because Peterson did not timely respond to his "requests for admission" (written questions a party must admit or deny), those matters should have been automatically treated as admitted. The court held that even if the trial judge erred, any error was harmless: Carrera was allowed to question Peterson about the same subjects at the hearing, and the judge decided the case on its merits. The court also noted that in custody cases involving domestic violence, all information must be considered, and sanctions that block evidence are disfavored. On domestic violence, the court held that the special rebuttable presumption in NRS 125C.0035(5) did not apply because that presumption only applies when a parent or another person seeking custody committed the violence - and Daniel was neither a parent nor seeking custody. The court found the trial judge did properly consider the domestic violence as a best interest factor. On the remaining best interest findings and the bias claim, the court held Carrera did not show the findings lacked support or that the judge acted out of improper bias. The appeals court also stressed that it could not reweigh evidence or credibility.

Lynn and Douglas McKendry divorced in 2020. As part of their property settlement, they agreed to keep owning two California homes together after the divorce - one in Palm Desert and one in South Lake Tahoe. Lynn was responsible for the Palm Desert debts, and Douglas for the South Lake Tahoe debts. In 2023, Lynn asked the court to enforce the agreement, saying Douglas had not paid the South Lake Tahoe bills. During a court hearing, the two reached a new, comprehensive settlement resolving all their disputes. Under the resulting amendments to the divorce decree, they agreed to list the South Lake Tahoe home for sale by May 2024, with Douglas "take[ing] the lead" in dealing with the realtor while keeping Lynn informed through his lawyer. They would split the sale proceeds equally after paying off the mortgage, and both agreed to stay out of the home and remove their belongings so it could sell quickly. Lynn also agreed to buy out Douglas's interest in the Palm Desert home. In October 2024, Douglas went back to court, claiming Lynn had moved into the South Lake Tahoe home and was blocking its sale by refusing to cooperate or communicate with him. The district court found the property had not sold because of the parties' dispute and that foreclosure was imminent. To prevent the asset from being lost, the court gave Douglas legal authority to list the property, hire a realtor, and accept an offer on behalf of both parties; barred Lynn from interfering with the sale; and allowed Douglas to retrieve his personal belongings. Lynn appealed. The Court of Appeals rejected each of her arguments. First, it held the district court acted within its authority in letting Douglas oversee the sale and in directing that sale proceeds go into his lawyer's trust account - an account lawyers must maintain to safeguard money belonging to clients and other people. To the extent Lynn argued Douglas should have sold his share of the home to her instead, the court noted the amendments never provided for one party to buy out the other's equity in that property, and courts cannot rewrite an agreement to add terms the parties never agreed to. Second, the court held that even though the property sits in California, the Nevada court had authority to act because it had personal jurisdiction over both parties - meaning power over the people themselves - and that jurisdiction continued through post-divorce proceedings arising from the original case. Third, Lynn claimed the district judge was biased against her based on a personal relationship with Douglas's lawyer. The court found she did not describe the relationship and pointed only to the judge's acceptance of a routine filing showing a realtor had been hired. That single act, the court said, did not show bias, and Lynn had not shown the kind of "deep-seated favoritism or antagonism that would make fair judgment impossible" needed to disqualify a judge. Finally, Lynn argued that she agreed to the settlement under duress, which would make the amendments to the decree void. Because that argument attacked the amended decree itself, and Lynn never filed a timely appeal from that decree, the appellate court concluded it lacked jurisdiction - legal power - to consider that part of her appeal and dismissed it.

Dirk and Valerie Paul married in July 2017, had two children, and divorced after Dirk filed for divorce in March 2022. Before trial, they agreed on custody, child support, and alimony. The trial then focused on how to divide the property they acquired during the marriage (called "community property" in Nevada) and how much Dirk owed in unpaid child support that had built up while the case was pending. The district court decided Dirk was holding more of the couple's shared property than Valerie, so it ordered Dirk to make an "equalization payment" of $105,414 to Valerie - a payment meant to even out the split. A big part of that decision rested on $100,000 Dirk took out of a Wells Fargo account after the couple separated. Dirk said that money went to repay a loan from his mother and grandmother that the couple had used to buy or fix up the marital home. The court also found Dirk owed $16,745 in back child support, ordered him to keep paying $1,000 a month in child support (an amount the parties had agreed to), and said it would later issue a separate order awarding Valerie attorney fees. On appeal, the Court of Appeals addressed three issues. First, on the money question: the appellate court agreed with the district court that the $100,000 was community property and not repayment of a family loan. Dirk had no documents proving the loan or how the money was spent, his testimony and his mother's testimony did not match up, and the trial judge found them not credible. Appellate courts do not second-guess a trial judge's decisions about who is telling the truth. So the finding that the $100,000 was shared property stood. But the appellate court found a separate problem: even accepting that the $100,000 was community property, the actual dollar figure the court ordered - $105,414 - ended up giving Valerie more than half of the couple's shared property. Nevada law generally requires an equal split unless there is a "compelling reason" for an unequal one, and if a judge splits things unequally, the judge must write down the reasons. The district court did not make those findings, so the appellate court reversed the property award and sent it back for the district court either to divide things equally or to explain in writing why an unequal division is justified. Second, on child support: because the parties had agreed on the $1,000 monthly amount before trial and Dirk never raised his objection with the district court, the appellate court held he gave up (forfeited) the argument on appeal. If he wants to change the amount, he must first ask the district court to modify it. Third, on attorney fees: the district court had only said it intended to award fees and had asked Valerie's lawyer to submit more information; it had not yet entered an actual order setting an amount. Because no final fee order existed when Dirk filed his appeal, there was nothing final for the appellate court to review. The court dismissed that part of the appeal without prejudice, meaning Dirk can challenge the fee award later once a final order is entered.

Todd and Tracy Elwardt married in 2013. In October 2023, Tracy filed for divorce, asking the court to divide their property and to award her alimony (financial support paid by one spouse to the other). After a trial, the district court divided the couple's property and gave Tracy support. Among other things, the court awarded Tracy four dogs valued at $2,000, half the equity in the marital home, and half of roughly $400,000 in sales commissions Todd earned during the marriage but had not yet been paid. The court also ordered Todd to pay Tracy $4,000 per month for four years (periodic alimony) and $24,000 over two years (rehabilitative alimony, meant to help her get training or education). Todd appealed and raised several arguments. First, he said two of the dogs, Fiona and Enzo, were gifts to him and therefore his own separate property, or that the court valued the dogs incorrectly. The appeals court explained that property acquired during a marriage is presumed to belong to both spouses (community property) unless someone proves otherwise with strong evidence. Because the dogs were acquired during the marriage, and because Tracy had been caring for them while Todd had limited contact, the court concluded Todd had not proven they were his separate property. On the value, only one dog's cost ($2,000) was proven at trial, so the court accepted that figure. But the appeals court noted the decree did not make clear whether Todd received other property to make up for his share of the dogs' value, and directed the lower court to fix that on remand. Todd's main challenge concerned the connection between the commissions and the alimony. Todd is paid entirely on commission, and those commissions are not paid to him until a client pays the underlying sales contract - which can take up to three years. That means in the years right after the divorce, much of Todd's monthly income could come from commissions he earned during the marriage, half of which the court had already awarded to Tracy. The appeals court agreed the commissions counted as community property, but found the district court did not adequately account for the fact that handing Tracy her share of those commissions would reduce Todd's income while boosting Tracy's finances. Because the court did not make specific findings on how this affected Todd's ability to pay and Tracy's need, the appeals court vacated (canceled) the $4,000-per-month periodic alimony award and sent it back for the district court to reconsider with proper findings. The appeals court rejected Todd's other arguments. On the marital home, Todd argued the money should be traced back to homes he owned before or during the marriage as his separate property. The court explained that when separate property is put into a jointly owned home during marriage, it is presumed to be a gift to the community unless proven otherwise, and Todd had not overcome that presumption - the home was in joint tenancy, mortgage payments came from shared funds, and Todd himself acknowledged Tracy had "earned" being on the title. On rehabilitative alimony, the court found Tracy's testimony about the cost and time to finish her master's degree supported the $24,000 award. Finally, Todd asked that a different judge handle the case on remand, arguing the judge formed negative opinions of him (the decree mentioned Todd spoiling Tracy's medication, writing derogatory notes on support checks, and reducing the functionality of Tracy's Tesla). The court presumed judges are unbiased and found the judge's comments came from what the judge learned during the case, not from an outside source, and did not show deep-seated antagonism. Importantly, the court said the district court did not actually rely on that conduct in deciding alimony or property. So the case did not need to be reassigned.

Steven Fisher and Beatriz Wing married in 2011 and divorced in October 2023. After the divorce decree was entered, Wing asked the court to reconsider, and the district court issued an amended decree that divided their shared (community) property unequally, awarded Wing monthly alimony (financial support paid after divorce), and awarded Wing attorney fees. Both sides appealed the first time. In that earlier appeal, the Court of Appeals upheld some of the district court's decisions and reversed others. Specifically, it agreed that a motorcycle and a life insurance policy were community property, and it upheld alimony of $1,200 per month for five years. But it reversed the court's classification of a retirement account (the NYL IRA) as community property because the findings were insufficient, reversed the court's finding that Fisher had "wasted" marital money, and vacated the attorney fee award because the court's explanation for reducing it did not hold together. The case went back to the district court to fix these issues. On remand, the district court again concluded that the NYL IRA was community property, found that the alimony was $1,200 per month for five years, and recalculated the attorney fees, awarding Wing $37,419.25 (paid partly in cash and partly by reducing Fisher's claim against the marital home). In this second appeal, Fisher raised several arguments. He said the court should have moved the case to a different county (a "change of venue"). The Court of Appeals explained that Lander County was the proper place because both people lived there when the case began and the property was there, and Fisher did not provide sworn statements showing that he or witnesses would be genuinely inconvenienced. Fisher also argued the NYL IRA should be his separate property because the money came from an account he opened in 2007, before the marriage. The court explained that property obtained during a marriage is presumed to be shared, and the spouse who claims it is separate must prove that with strong ("clear and convincing") evidence. Because Fisher did not provide records tracing the money in those accounts during the marriage, he did not meet that burden. Several other property arguments Fisher raised - about a lien on the home, the value of life insurance policies, Wing's Disney retirement account, and alleged stolen assets and forged checks - were rejected because he had not raised them in his first appeal, so they were outside the scope of the remand and could not be raised now. On alimony, the court said its earlier decision upholding the $1,200-per-month, five-year award had become the "law of the case" - a rule that, once decided on appeal, must be followed afterward - and Fisher gave no reason to depart from it. On attorney fees, Fisher argued the award was unfair because he was indigent. The court noted that although he filed paperwork seeking to proceed as a poor person, he also paid the filing fee, so the Nevada Supreme Court took no action on that request. The court found the district court had properly considered the required factors and the parties' income difference, and Fisher did not challenge those findings. Finally, Fisher argued the judge was biased. The court explained that disagreeing with a judge's rulings is generally not enough to show bias; a party must show the judge relied on outside information or showed deep-seated favoritism or antagonism making fair judgment impossible. Fisher did not make that showing. The Court of Appeals affirmed the district court's judgment.

Edward and Kelley Sachetti were divorced under a decree (the final court order ending a marriage and dividing property) filed in April 2024. A few months later, Kelley asked the court to enforce the decree, claiming that Edward had not had his home appraised as the decree required and had improperly subtracted money from the monthly pension payments he owed her. She also asked the court to make Edward pay her attorney fees for the cost of forcing him to comply. Edward opposed her request. He argued that the decree contained errors and included terms the parties had never actually agreed to at their settlement conference (the meeting where they negotiated the terms of their divorce). In particular, he claimed they never agreed to reduce the appraised value of Kelley's real estate by $131,000 to account for her mortgage, and he argued that the part of the decree equalizing Social Security income violated federal law. The district court enforced the decree, finding that Edward had not shown the written terms differed from what the parties agreed to. It later awarded Kelley $11,108.34 in attorney fees and $85.09 in costs for litigating the enforcement motion. Edward appealed. The Court of Appeals affirmed. It explained that Edward did not raise his main arguments (about the $131,000 reduction and the Social Security issue) when he first responded to Kelley's enforcement motion, so those arguments were forfeited - lost because they were not raised at the right time. Even treating his later reconsideration motion as raising those points, the court found no abuse of discretion, partly because Edward failed to provide transcripts of the settlement conference and the enforcement hearing. When an appellant leaves necessary documents out of the record, the appellate court assumes those missing documents would have supported the lower court's decision. On the attorney fees, the court rejected Edward's claim that he was denied notice and a chance to be heard. Both sides had requested fees, the court directed Kelley to submit supporting information, and Edward filed an opposition - so he had notice and an opportunity to respond. The court also found that the district court properly considered the required factors, evaluated how much each member of Kelley's legal team worked, considered the difference in the parties' incomes, and found Edward's position frivolous because he did not back it up with citations to the record. The fee award was supported by sufficient evidence, so the appellate court left it in place.

Robert and Lisa Follett filed a joint petition for divorce in February 2025. In that petition, Robert agreed to pay Lisa $1,000 per month in alimony (financial support paid by one ex-spouse to the other) on the first of each month. The petition did not say how long these payments would last or when they would start. The district court granted the divorce and adopted the alimony terms exactly as written in the joint petition. Soon after, Lisa asked the court to clarify the decree. She argued that the decree left out how long the alimony would last, and she said the parties had intended a ten-year period of payments starting March 1, 2025. Robert responded by asking the court to set aside (cancel) the divorce decree. He claimed fraud: he said the version of the joint petition he reviewed and signed actually stated that neither spouse would pay the other alimony, and that Lisa had changed the petition before filing it. He wanted the court to vacate the decree and enter a new one saying neither spouse owed alimony. The district court held an evidentiary hearing, where both sides gave testimony and presented evidence, including Robert's paystub. The court then granted Lisa's request to clarify the decree and denied Robert's request to set it aside. The court found that the evidence showed the parties intended Robert to pay $1,000 per month for a five-year period, and that Robert had not proven the alimony award was obtained by fraud. On appeal, Robert argued the district court misread his paystub and failed to consider certain statutory factors. But there was a significant problem with his appeal: he never ordered transcripts of the evidentiary hearing, even after the supreme court specifically sent him a notice telling him he had 14 days to either request a transcript or file a certificate saying he was not requesting one. He did neither. Because the appellate court did not have a transcript of the hearing, it presumed the missing transcript supported what the district court decided. The Court of Appeals also explained that the district court was not deciding whether to award alimony or setting the amount for the first time — those terms were already final because Robert had agreed to them in the joint petition and they were incorporated into the divorce decree. Neither party had asked to change the alimony based on a change in circumstances. Instead, Lisa only asked the court to clarify an alimony award that already existed. For that reason, the court was not required to make the statutory findings that apply when a court is actually awarding or setting alimony. The Court of Appeals concluded that the district court did not abuse its discretion and affirmed the decision.

Marc and Joanna Savard married in 1998, had four children, and divorced after Marc filed for divorce in 2020. Following a lengthy trial, the district court issued a decree of divorce addressing child custody, child support, division of the couple's property and debts, and alimony. The court later issued an amended decree to fix a child support calculation error and clarify several points. Marc appealed, raising a series of challenges. The Court of Appeals rejected all of them and left the district court's decisions in place. First, Marc argued the district court had no authority (jurisdiction) to enter the amended decree because he had already filed his notice of appeal. The appellate court explained that under the appellate rules, a notice of appeal filed before the final written order is entered is treated as premature and does not strip the district court of its power to enter that order. Because Marc filed his notice before the amended decree was entered, the district court still had jurisdiction. Second, Marc challenged the custody decision. He wanted primary physical custody and wanted to move with the children to Canada. The trial court instead awarded joint physical custody and refused the move. The trial heard testimony about incidents in which Joanna threw a water bottle that bounced near a child, forcibly took the children's phones, and kicked a hole in a wall. Joanna explained she had been under stress from the divorce and had learned to handle it better. The district court found these incidents inappropriate but not acts of domestic violence. The appellate court said custody decisions are reviewed for "abuse of discretion" - a deferential standard - and that it will not second-guess the trial judge's findings if a reasonable person could accept the supporting evidence. It also said appellate courts do not reweigh evidence or re-decide who was believable. On the request to move to Canada, the district court applied a test that asks, first, whether the parent has a "sensible, good faith reason for the move," and then weighs several additional factors about quality of life and visitation. The court found Marc's claimed benefits - climate, schools, healthcare, and family proximity - were largely speculative. It noted, for example, that Marc listed only $432 a month in health insurance costs and that higher Canadian taxes undercut his claim of major savings. The court concluded Marc actually wanted to move to interfere with Joanna's relationship with the children, and that there was no realistic way for Joanna to keep a meaningful relationship if the children moved. The appellate court found these findings supported by the evidence. Third, on child support, Marc argued the court wrongly counted his girlfriend Kate's income, wrongly imputed income to him, and should have reduced his obligation for paying the children's health insurance. The appellate court found the record showed the court considered Marc's own wages (including the $8,000 a month he earned working for Kate's business and about $4,700 a month net from cruise-ship performances), not Kate's income, and that the court did not impute income. It upheld the support amounts. Fourth, on dividing property and debts, the law generally requires an equal split unless there is a "compelling reason" for an unequal one. The district court found Marc committed financial misconduct - misrepresenting community finances, overstating business expenses, filing financial disclosure forms with inflated figures, failing to fully account for more than $400,000 in pandemic grant money received by the couple's company (MSI), and using community funds after separation on cryptocurrency and a stock-trading venture that lost substantial money. The court found Marc "intentionally manipulated community monies and strategically mislead the court" to disadvantage Joanna. Even though Joanna conceded the court misread one line on a 2022 tax filing, the appellate court found that error harmless because of the court's many other supported findings, so the unequal division stood. Fifth, on alimony, the district court awarded Joanna permanent, periodic alimony until her remarriage or the death of either party, and ordered Marc to keep a life insurance policy naming Joanna as beneficiary to secure the alimony and child support. The court found Marc's earning capacity superior given his talent and experience, that Joanna had been a full-time homemaker and primary caregiver for 18 years, that the marriage was long, and that the couple had enjoyed "a very comfortable, upper-class standard of living." The appellate court upheld the award. Sixth, on attorney fees, the district court awarded fees to Joanna, citing the income disparity between the parties and finding Marc had maintained his relocation request "without reasonable grounds and to harass Joanna." It also reviewed billing records and analyzed the required factors about counsel's skill and the work involved. The appellate court upheld the award and also upheld the court's refusal to award Marc fees for an earlier motion, partly because Marc had not timely filed a required financial disclosure form and did not make a developed argument on appeal. Finally, Marc argued the judge denied his motion to alter or amend improperly and was biased against him. The appellate court found the judge simply did not believe Marc's version of events, which is a credibility call within the judge's discretion, and that Marc did not show the kind of "deep-seated favoritism or antagonism that would make fair judgment impossible" needed to establish bias. The court affirmed the entire judgment.

Ronald and Vernieta Marquart, who married in 2000, divorced through a joint petition that included a clause requiring Ronald to pay Vernieta a set amount of alimony (court-ordered support payments to a former spouse) on the first of each month. The district court entered a divorce decree in August 2024 ordering alimony as the parties had agreed. In January 2025, Vernieta filed a motion alleging Ronald had failed to pay alimony as ordered and asking the court to enforce the decree. Ronald responded with his own request asking the court to reduce his alimony obligations. After a hearing, the district court gave Ronald partial relief - it limited his alimony obligation to 12 years after entry of the divorce decree - but otherwise denied his request. Ronald appealed. The Court of Appeals of Nevada affirmed, meaning the district court's decision stands. Ronald's main argument was that his income had dropped since the divorce, so his alimony should be reduced. But the district court had found his monthly income had "barely changed" - it was $8,599 at the time of the hearing compared to $8,620 when the divorce decree was entered - so he had not shown the kind of changed circumstances that would justify lowering the monthly payments. Ronald did not challenge those specific findings on appeal. He also did not provide the appellate court with a transcript of the district court hearing; in fact, he filed a certificate stating he was not requesting transcripts. Under Nevada's appellate rules, it is the appellant's job to supply the transcripts needed to review the appeal, and when the transcript is missing, the appellate court presumes the missing record supports the lower court's decision. Ronald also raised a new argument on appeal - that his alimony is too high because he now has a vehicle payment - but because he did not present that argument to the district court first, the appellate court would not consider it. Finally, Ronald argued the district court violated a Nevada statute, NRS 125.165, by considering income he receives from military disability benefits. The Court of Appeals disagreed, relying on a recent Nevada Supreme Court decision, Oshiro v. Oshiro, which held that the statute bars a court from directly dividing military disability benefits for alimony purposes but does not bar a court from considering those benefits as part of a broader look at the couple's finances and ability to pay. Although Oshiro was decided after the district court ruled, the Court of Appeals explained that a later judicial interpretation of a statute can still be used to evaluate whether the district court's legal conclusions were correct.

Edgar and Jenny Tavares married in August 2016. In March 2021, they jointly asked the court for a "summary" divorce - a streamlined process that married couples can use when they agree on the terms. In April 2021, they submitted a stipulated decree (an agreement they both signed and the court adopted) that divided their property. Under that agreement, Jenny received three properties - the Cedar Street, Rockville Creek, and Prosperity River properties - plus her own 401(k) retirement account, while Edgar kept his own 401(k) account. About 18 months later, in November 2022, Edgar asked the court to undo the decree. He argued the property split was unfair, and that Jenny had taken advantage of his low emotional state to get him to sign an agreement that favored her. He used a court rule, NRCP 60(b), which lets a court set aside a final judgment for certain reasons. The catch is that most of those reasons must be raised within six months. Edgar argued his clock never started because he never received formal notice that the decree had been entered, and he also pointed to a part of the rule - NRCP 60(b)(6) - that allows relief for "any other reason" and is not bound by the six-month deadline. Jenny opposed the motion. She argued it was too late, that Edgar had waived his right to formal notice by using the summary divorce process, and that he had in fact received the decree and notice in the mail. She also noted that a separate statute, NRS 125.150(3), gives more time to reopen a divorce when assets are left out of the decree because of fraud - but she said that statute did not apply because Edgar was not claiming any asset had been omitted; he was simply unhappy with the deal. The district court denied Edgar's motion as untimely and ruled it lacked jurisdiction to revisit the property terms. Edgar appealed. The Court of Appeals affirmed. It explained that summary divorce decrees are final judgments and that the deadlines in NRCP 60 apply to them. Because Edgar filed roughly 18 months after notice of entry, his claims under the deadline-bound parts of the rule were too late, and that six-month deadline cannot be extended. The court also rejected Edgar's argument that he never received notice. It noted he did not properly develop that argument on appeal, so the court did not have to consider it. But even considering it, the court found the argument failed: by using summary divorce, Edgar waived his right to written notice; Jenny's attorney filed a sworn statement that she mailed the decree and notice to Edgar's last known address; and the record showed Edgar clearly knew about the decree - he signed deeds transferring property to Jenny shortly afterward, and he testified he gave the decree to a loan officer in December 2021 to get a home loan. Yet he waited until November 2022 to act. On the "any other reason" provision, NRCP 60(b)(6), the court explained that this catch-all is reserved for "extraordinary circumstances" where the party is faultless in the delay, and it cannot be used when the complaint really fits one of the other listed reasons. Edgar's core complaint - that Jenny manipulated and fraudulently induced him - fit the fraud category of NRCP 60(b)(3), so the catch-all was unavailable. He also did not show he was faultless in waiting nearly a year after he knew about the decree. Finally, the court rejected Edgar's reliance on the omitted-assets statute, NRS 125.150(3). He claimed the parties' 401(k) accounts were left out of the decree, but the court pointed out the decree plainly awarded each party their own 401(k), so nothing was omitted.

This case grew out of a divorce between Gonzalo Ramos and Maria Luisa Sanchez-Plata. In 2023, the couple agreed to a divorce decree that gave Ramos a piece of real property as his separate property, but required him to pay Sanchez-Plata $41,000 as an "equalization payment" (a payment to balance out the division of community property) from the sale of that property. The decree was later set aside, and the marriage was declared void. On April 5, 2024, however, the district court kept the same community-property division in place using the "putative spouse doctrine," which protects spouses who believed in good faith they were married even if the marriage turns out to be invalid. When Ramos said he could not refinance or otherwise pay the $41,000, the district court issued a September 23, 2024, order directing that the property be sold. Then, on June 25, 2025, the court found that Ramos was blocking the sale by refusing to cooperate with the listing agent and refusing to show the property. The court ordered him to vacate the home and gave exclusive possession to Sanchez-Plata so the sale could go forward. The June 25 order also reduced the $41,000 award to a formal judgment for enforcement purposes and denied Ramos's countermotion to dismiss or pause the proceedings. Ramos appealed the June 25 order. The Nevada Supreme Court dismissed the appeal because it concluded it had no jurisdiction to hear it. Nevada appellate courts can only hear appeals that a statute or rule specifically allows. The court explained that the June 25 order was not a "final judgment" because the underlying divorce issues had already been finally resolved by the April 5, 2024, order. Reducing the $41,000 amount to a judgment for collection purposes did not create a new final judgment that could be appealed. The court also rejected Ramos's argument that the order was an appealable "special order after final judgment" because it forced him out of the home. Under the prior orders, Ramos never had an absolute right to keep living in the property; the property was always supposed to be sold (or refinanced) to fund the equalization payment. So the June 25 order requiring him to leave was simply enforcing what had already been decided, not changing his rights. Because no statute or rule allowed an appeal from this kind of enforcement order, the Supreme Court dismissed the case.

Samuel and Jeannette Vasquez were married in October 1996. In August 2022, Jeannette filed for divorce. Because their children were already adults and there was no custody dispute, the court's job was to divide the couple's property and debts and decide whether Jeannette should receive alimony (regular financial support paid by one former spouse to the other). At an evidentiary hearing (a court session where both sides present testimony and evidence), Jeannette testified that she had mostly been a homemaker raising the children during their nearly 28-year marriage and had worked as a teacher for the last ten years. She earned about $4,333.33 per month as a teacher and received $524.31 per month in disability income from the U.S. Department of Veterans Affairs (VA) for chronic heart disease. She asked for $2,000 a month in alimony for fifteen years. A central dispute was about money in Samuel's Chase savings account. According to the records, Samuel had disclosed $230,000 in that account, but a later disclosure showed the balance had dropped to $20,000 over about seven months - a reduction of roughly $210,000. Jeannette argued Samuel had spent this money deliberately so she would not get her share of it. Samuel said he worked as a director at a healthcare company earning $8,333.33 per month and also received $4,250 per month in rental income from a California property that he had not listed on his financial disclosure forms. He testified that the money in the Chase account came from a gift or inheritance from his mother. When asked how he spent $210,000 in seven months, he said he did remodeling projects and paid bills, but he also acknowledged credit card and bank charges for international travel with his girlfriend. The district court did not find Samuel's explanation credible. Because the money had been deposited during the marriage, the court treated it as community property (property belonging to both spouses). The court found Samuel failed to show the money was a gift and failed to credibly explain where the $210,000 went. The court concluded the spending was "marital waste" - using shared property for selfish purposes unrelated to the marriage at a time the marriage was breaking down. To make up for half of the wasted money, the court awarded Jeannette $105,000. The court also awarded Jeannette $2,000 per month in alimony for ten years, after weighing factors such as the length of the marriage, the difference in the spouses' incomes, Jeannette's role as a homemaker and teacher, and Samuel's higher income and income-producing property. On appeal, Samuel argued the waste finding was not supported by the record, that Jeannette suffered no economic harm, that he had no intent to deprive her of her share, and that she did not need alimony. The Court of Appeals rejected these arguments. It explained that appellate courts do not re-weigh witness credibility, that substantial evidence supported the district court's findings, and that Samuel had not even provided the appellate court with the bank and credit card records from the hearing - so the court presumed those records supported the lower court's findings. The Court of Appeals affirmed the divorce decree in full.

Raul and Rosalba Lopez married in May 2014 and have two children. In September 2022, Rosalba filed for divorce. The couple agreed on how to handle custody of their children - they would share joint legal and physical custody, and Rosalba would pay Raul child support. That left only two things for the court to decide: whether Raul should receive alimony (financial support paid by one spouse to the other after divorce), and whether attorney fees and costs should be awarded. At a hearing in September 2023, both Raul and Rosalba testified about their finances. Rosalba works full-time as an operations supervisor at a freight company. She testified that she supports the parties' daughter, J.L., who turned 18 during the case and continued to live with her, and that she covers her own household and medical costs, including treatment for breast cancer and a skin removal surgery that insurance did not cover. Her position was that she could not afford to pay Raul alimony. Raul testified that he has not worked since 2018 and receives Social Security Disability benefits. He said he wanted alimony so he could move out of his parents' home, where he has lived since the separation, and he argued that Rosalba exaggerated her expenses and could afford to pay him. The district court weighed the factors the law requires it to consider for alimony. It found Rosalba's net monthly income (after tax deductions) to be $5,984.27 and her expenses to be $5,477. It found Raul's gross monthly income from Social Security Disability benefits to be $1,856.90 and noted his expenses were limited. The court also noted that Raul had covered his own living expenses for about a year after moving out without Rosalba's help, and that both parties would receive an equal lump sum from selling the marital home. The court concluded that Raul did not show a need for support that outweighed the burden such payments would place on Rosalba, and that Rosalba did not have the ability to pay alimony. The court denied alimony and indicated Rosalba would be awarded attorney fees and costs, with a separate order to follow on the amount. On appeal, Raul argued that the court should not have counted Rosalba's spending on their adult daughter, that Rosalba's expenses were inflated, and that some of her medical expenses were unnecessary. The Court of Appeals disagreed. It explained that the law requires the court to consider each spouse's financial condition, which includes their expenses. Raul did not point to any legal authority showing the court could not consider these particular expenses. The appellate court also explained that Raul was essentially asking it to re-weigh the evidence - to decide which testimony was believable and how much weight it deserved - which is the job of the trial court, not the appellate court. Because the trial court's findings were supported by the evidence and Raul identified no legal error, the Court of Appeals found no abuse of discretion and affirmed the denial of alimony. The court also addressed a few side points. It noted that Raul's challenge to the attorney fees award was premature, because the decree contemplated further proceedings to set the fee amount and no final order on fees had been properly appealed. And it treated two mistakes in the decree - a reference to Rosalba obtaining a high school diploma when she did not finish high school, and a statement that the marriage occurred in 2015 instead of 2014 - as harmless clerical errors that did not change the analysis.

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

Cherlyn and Robert Oshiro married in 1999 in Las Vegas. Robert had served in the military, including four years in the Vietnam War, and received a service-connected injury. Throughout the marriage, the couple lived in part on Robert's military disability benefits. After Cherlyn stopped working in 2007 following a car accident and Robert retired in 2013, the couple lived on Robert's military disability benefits and their combined Social Security benefits, with Cherlyn serving as Robert's primary caretaker as his disability worsened. Cherlyn filed for divorce in 2023. The parties resolved how to split their shared property on their own, leaving only the question of alimony - ongoing financial support paid from one ex-spouse to the other - for the trial judge. At the time of trial, Robert received $3,946.25 per month in military disability benefits and $2,071 per month in Social Security benefits; Cherlyn received $998 per month in Social Security benefits. Cherlyn asked for $3,400 per month. Robert argued the court could only look at the couple's Social Security benefits and proposed $536.50 per month. The district court awarded $2,000 per month. Robert appealed. His main argument was that a Nevada statute, NRS 125.165, forbids courts from dividing a veteran's military disability benefits when setting alimony, and that the statute also forbids courts from even considering those benefits in the calculation. He argued the $2,000 award - which would require him to hand over about 96.6 percent of his Social Security income - effectively divided his disability benefits in disguise. The Nevada Supreme Court rejected that reading. The court held that NRS 125.165 prohibits direct actions against the benefits themselves - attaching, levying, seizing, assigning, or dividing them - but does not prohibit a court from considering that those benefits exist and contribute to a divorcing veteran's overall financial picture. The court relied on the plain text of the statute, the legislative history (an earlier draft contained the word "consider" but the legislature deliberately removed it), and the rule that words in a list take meaning from their neighbors - here, all the prohibited verbs describe collection actions, not passive consideration. The court also distinguished two U.S. Supreme Court cases Robert cited, Mansell v. Mansell and Howell v. Howell, explaining that those cases involved community property division and waivers of military retirement pay, not alimony. The court noted that Howell expressly left state courts free to take a veteran's disability benefits into account when evaluating need for alimony, and that the overwhelming majority of state courts allow consideration of such benefits in alimony determinations. Reviewing the $2,000 award itself for abuse of discretion, the court found substantial evidence supported it - the trial court considered both spouses' financial conditions, earning capacities, ages, health, home contributions, and standard of living. The court acknowledged that the award came "just up to that line" because Robert would have to pay nearly all of his Social Security benefits to satisfy it, but observed that the district court did not order him to pay from his disability benefits. The court expressly reserved for another day the harder question of whether NRS 125.165 would invalidate an alimony award that could only be paid by drawing from military disability benefits.

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

Leslie and Paul Fassari married in California in 2012 and have no children together. They later moved to South Carolina, separated around June 2, 2024, and Leslie moved to Las Vegas. On November 5, 2024, she filed for divorce in Nevada's family court. In her complaint she asked the court not only to end the marriage but also to divide the couple's property, identify which property each owned before marriage as separate property, decide a claim of "marital waste," award her spousal support (alimony), and award her attorney fees and costs. She served Paul outside Nevada under a court rule allowing service elsewhere in the United States (NRCP 4.3(a)). Paul did not answer the complaint. Instead, he asked the court to dismiss the case, arguing the Nevada court did not have "personal jurisdiction" over him - that is, legal authority over him as an individual. Without that authority, he argued, the court could not decide property division, marital waste, or alimony. He also asked the court for his own attorney fees and costs for having to bring the motion. Leslie responded that Paul had actually submitted himself to Nevada's authority by asking for attorney fees and costs - in legal terms, by seeking "affirmative relief." She also argued that even if the court lacked authority over Paul personally, it could still simply dissolve the marriage based on its "in rem" jurisdiction (authority over the status of the marriage itself, which exists when one spouse genuinely lives in Nevada). She noted that South Carolina law would not let her file for divorce there until one year after separation. The district court dismissed the entire complaint. It found Paul had no ties to Nevada, that requesting attorney fees did not waive his jurisdiction objection, and that it could not exercise personal jurisdiction over him. It then declined to dissolve the marriage by itself, reasoning that splitting the divorce from the property issues is disfavored in Nevada and would create "numerous problems." The Court of Appeals reached a split result. On the personal-jurisdiction question, it agreed with the district court: Paul's request for attorney fees and costs was not "affirmative relief" and did not submit him to Nevada's authority, so the court correctly found it could not decide the property, waste, and alimony issues. But on the divorce itself, the appellate court disagreed with the dismissal. It explained that a "divisible divorce" - dissolving the marriage now while leaving the money-and-property issues for another court that has authority over both spouses - is different from the "bifurcated divorce" disfavored in older Nevada cases. The court held that if a person meets the statutory requirements for divorce (including living in Nevada at least six weeks), the district court does not have discretion to refuse the divorce. Because the district court never analyzed whether Leslie met those requirements, the appellate court sent that part of the case back for the district court to decide.

Conrad and Heidi Roberson were married, had two children, and divorced in 2018-2021 after extensive litigation. After their divorce was finalized by a stipulated decree in October 2021, Conrad asked the trial court to change the decree and the child-custody arrangement. The trial court said no, and Conrad appealed that decision. While that earlier appeal was still going on, Heidi went back to the trial court and asked it to order Conrad to pay $25,000 to help cover her lawyer costs in fighting the appeal. (This kind of payment is called "pendente lite" attorney fees - fees a court orders during an ongoing case so one party can carry on or defend the suit.) Heidi explained that Conrad was behind on what he owed under the decree, and her lawyer noted that the appeal had been removed from the settlement program, with a briefing schedule already set. The trial court agreed and ordered Conrad to pay the $25,000, pointing to a large gap in the parties' incomes: Heidi earns about "$50,000 a year along with court-ordered child support and alimony," while Conrad earns approximately $500,000 a year. Conrad then filed a motion asking the court to reconsider (a "motion to alter or amend") and to pause the order. He argued that the court did not properly weigh his finances - including the alimony and child support he already pays Heidi - and that the fee award was not actually connected to the future appellate work that still needed to be done. The trial court rejected those arguments. It also found that Conrad had acted in bad faith by refusing to pay and continuing what it described as litigation games, and on that basis awarded Heidi an additional $10,975.32 in attorney fees under a separate statute that allows fees against a party who brings claims without reasonable grounds or to harass. Conrad appealed both fee awards. On appeal, the Court of Appeals of Nevada affirmed - meaning it upheld the trial court's decisions. The court explained that because Heidi asked for the fees while the appeal was still pending and before briefing was filed, the award was properly tied to future appellate work. It also concluded the trial court had adequately considered both parties' financial circumstances, including the income gap and Conrad's existing payments. As for the additional fee award, the court found there was enough evidence in the record to support the trial court's conclusion that Conrad's reconsideration motion lacked reasonable grounds and was brought in bad faith. The court also denied Heidi's request for sanctions on appeal.

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

This case concerns the difference between a divorce and an annulment, and what a court must prove before it can declare that a marriage never legally existed. Maria Rosa Dos Santos, who is originally from Argentina and was living in the United States on an expired visa, met Mark Vincent Dreibelbis, a U.S. citizen and Nevada real estate agent, through a dating app in late 2021. They married in Las Vegas in February 2022, despite a language barrier (Mark spoke English, Maria spoke only Spanish), and Maria moved in with Mark in Henderson. Mark supported Maria financially and began helping her apply for permanent residency, but the application was never filed because his real estate business struggled as mortgage interest rates rose. As their finances worsened, the relationship broke down. By October 2022, Maria had moved into a friend's home and told police that Mark had strangled her during a domestic violence incident. Police observed visible injuries, went to Mark's home, and arrested him; he denied the allegations. Mark was charged with domestic battery by strangulation, but the charge was later dismissed after Maria did not appear to testify. In May 2023, Maria filed for divorce. Mark responded by asking the court to annul the marriage - an annulment treats the marriage as if it was never valid, rather than ending a valid marriage as a divorce does. Mark claimed Maria married him only to get immigration benefits and that she had made up the domestic violence accusations to support an immigration petition. He submitted translated WhatsApp messages that he said showed Maria admitting she fabricated the abuse claims and used the marriage to get legal status. Maria denied writing the messages and said Mark - who had created her WhatsApp account and had access to her devices - fabricated them. Mark acknowledged he knew about her immigration status before the marriage and had agreed to support her and help her get documentation for legal residency. After a trial, the district court granted the annulment. It found that Maria had fraudulently induced the marriage solely for immigration purposes and that her domestic violence allegations were not credible, concluding that Mark had "sufficiently proven" his allegations. On appeal, the Court of Appeals agreed with Maria that the district court used the wrong standard of proof. Under Nevada law, a person seeking an annulment based on fraud must prove that fraud by "clear and convincing evidence" - a demanding standard. The trial court instead said only that Mark had "sufficiently proven" his claims, and it never identified or applied the clear-and-convincing standard. The appellate court also noted that the trial court never worked through the specific elements that make up fraud. Because of this, the Court of Appeals reversed the annulment and sent the case back so the district court can apply the correct standard and analyze the elements of fraud properly. The court added that if, on remand, the district court concludes Mark did not prove fraud by clear and convincing evidence, it should instead enter a decree of divorce.

Christopher Rowan and Heather Walker married in 2004, had two children, and divorced in June 2021 under a stipulated divorce decree (an agreement the divorcing spouses reach themselves that the court then adopts). Under the decree, Rowan was ordered to pay Walker both child support and alimony (ongoing payments to a former spouse). In June 2023, Rowan asked the court to lower both payments, saying his gross monthly income had dropped by more than 20 percent. Walker opposed the request. The district court denied Rowan's motion without holding a hearing. The court acknowledged that Rowan claimed a drop of more than 20 percent in his income, but concluded that his ability to earn had not actually changed and that any decrease resulted from his own voluntary decision to quit his job. The court also said that even if Rowan had shown changed circumstances, lowering child support would not be in the children's best interest, and it denied the alimony request for essentially the same reasons. While this appeal was pending, Rowan filed a second motion to modify support and alimony, claiming his income had fallen even further. The district court scheduled an evidentiary hearing (a hearing where parties present evidence) on that second motion, but said it would not revisit the earlier denial being appealed. Walker argued that the new hearing made this appeal moot - meaning there was no longer a live dispute for the court to decide. The Court of Appeals disagreed. It explained that any change resulting from the later motion would only affect payments from July 2024 forward and would not change the amounts at issue in this appeal, because payments that have already come due become fixed and cannot later be modified. So the appeal still presented a real controversy. On the merits, the Court of Appeals agreed with Rowan that the district court was required to hold a hearing once he presented preliminary evidence (a "prima facie case") that his income had dropped by more than 20 percent. Under Nevada law, a change of 20 percent or more in gross monthly income is deemed to be changed circumstances that require a review of a support or alimony order. The court emphasized that requiring a review is not the same as requiring a reduction - the judge still gets to decide, after the hearing, whether to actually change the payments. But the judge must hold the hearing first, because that is where evidence is presented and weighed, and skipping it deprived Rowan of a meaningful opportunity to be heard. Because no hearing was held, the Court of Appeals reversed the denial of both the child support and the alimony requests and sent the case back so the district court can hold an evidentiary hearing. The court also suggested that the district court could combine that hearing with the one already scheduled on Rowan's second motion, to reduce the burden on everyone, but it took no position on whether discovery would be necessary.

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

Natasha and Michael Neyman married in 2002, had two children, separated in 2006, and divorced in 2015 through an agreed-upon (stipulated) divorce decree. The decree gave Natasha primary physical custody and required Michael to pay child support, the children's extracurricular costs, and two kinds of spousal support (alimony): $3,000 per month in general family support and $2,000 per month in "rehabilitative" alimony to help pay for Natasha's education. To get the rehabilitative alimony, Natasha had to give Michael proof she was enrolled in school. These payments were to run for seven years, starting May 1, 2015, meaning the final payment was due April 20, 2022. Natasha stopped going to school at the end of 2020 because she and the children had health problems, and by January 2021 she was no longer enrolled. She did not give Michael proof of enrollment, but Michael kept paying her $2,000 per month for 15 more months — a total of $30,000. On June 30, 2022 — about two months after the alimony period ended — Natasha filed a motion asking the court to increase child support and family support because Michael's income had gone up sharply, and to recover money she said Michael still owed her. Michael agreed his child support should go up, but said his alimony obligation had ended in May 2022 and that he was not behind on any payments. The district court ruled that it had no power (jurisdiction) to change the alimony because the alimony period had already expired when Natasha filed her motion, and there was no evidence Michael was behind. It raised Michael's monthly child support to $4,035. It also found that Natasha had failed her duty to give proof of school enrollment for 15 months, but that Michael knew or should have known she was no longer in school. Splitting the difference, the court ordered Natasha to repay Michael $15,000 — half of what he had paid during that period — then subtracted $6,500 in attorney fees Michael still owed her, leaving Natasha owing Michael $8,500. The court found neither side was a "prevailing party," so each paid their own fees. On appeal, the Court of Appeals agreed with the district court on most points but reversed the order requiring Natasha to repay the rehabilitative alimony. The court explained that under Nevada law, once an alimony period ends, a court can only modify alimony if the paying spouse was behind ("in arrears") when the motion was filed. Here, the alimony period had ended on April 30, 2022, and Natasha herself had admitted Michael had made all his payments before she filed. The text messages she pointed to as a supposed agreement to push the start date back did not count, because the decree said it could only be changed by a written agreement signed by both parties. The most important reversal concerned the order that Natasha repay $8,500. The court found that Michael never properly asked for that money back. He mentioned in passing that he had overpaid, but he did not formally request reimbursement, and did not say how much, until his pretrial memorandum — filed after Natasha's lawyer had quit, after the discovery period closed, and just two weeks before the hearing. The court concluded this violated Natasha's right to fair notice and a chance to respond (due process). It therefore reversed the repayment order and directed that Natasha receive the full $6,500 in unpaid attorney fees with no reduction. The court also upheld the child support ruling (finding Natasha had not properly argued below that the base amount was too low for the children's needs), upheld the denial of her request to postpone the hearing, and upheld the court's refusal to accept her digital documents, which she needed to bring in physical form so they could be authenticated and so Michael could object.

Sharlena Polk and Charles Rowland married in 2007 and had two children. In 2020, Rowland filed for divorce and asked the court to divide the couple's shared (community) property. At a hearing on July 15, 2021, the couple told the court they had agreed on most issues - including child custody and many financial matters - but they had not agreed on what to do with the marital home. Rowland wanted to keep the home but first needed to see whether he could refinance the mortgage to buy out Polk's share. Polk did not want to keep the home and agreed to sign whatever paperwork was needed to let Rowland refinance or sell it. The couple did not agree on how much the home was worth or how much each person should receive from its value (its equity). At that same hearing, the court verbally declared the couple divorced but explained the marriage would not actually end until a written divorce decree was signed. The written decree was filed on December 16, 2021. In the decree, the court did not decide the home's value. Instead, it gave Rowland 90 days to either arrange a refinance and buy out Polk's share, or to sell the home. Rowland got an appraisal in August 2021 that valued the home at $360,000. He completed the refinance in May 2022. Using the older August 2021 value (and subtracting child support Polk owed), he calculated that Polk was owed about $56,000. Polk objected, pointing out that a more recent appraisal valued the home at $430,000, and argued Rowland improperly used the lower, older figure. Rowland responded that the couple became divorced at the July 2021 oral pronouncement, so the August 2021 appraisal was the right one to use. The district court agreed with Rowland, ruling that the marital community ended when the judge orally declared the couple divorced in July 2021, and that the home should be valued as of that date. Polk asked the court to reconsider, pointing to a Nevada Supreme Court decision, Kogod v. Cioffi-Kogod, which held that a marital community is not terminated by an oral pronouncement of divorce - it continues until the written decree is entered. The district court acknowledged the Kogod decision but stuck to its view and denied reconsideration. The Court of Appeals reversed. It held that the district court's conclusion that the marriage's community ended at the oral pronouncement conflicted with the binding Kogod decision and was therefore erroneous. Because of that error, the district court never made proper findings about what the home was worth when Rowland actually refinanced it - which is the moment the decree itself had set for distributing the value - or how much Rowland should have paid Polk. The court also rejected Rowland's argument that earlier court minutes had already settled the home's value, finding that no such agreement was ever reached. The Court of Appeals sent the case back to the district court to make specific findings using the home's appraised value at the time of the refinance and to divide that value fairly between the parties as the decree required.

Jesusa and Wayne Conte married in 1986 and divorced in 2012. Their divorce decree required Wayne, a military veteran whose only income comes from a retirement pension, supplemental security income, and veterans' disability income, to pay Jesusa $1,000 per month in alimony for 15 years. According to the opinion, Wayne refused to voluntarily pay, so Jesusa repeatedly had to go to court to garnish his pension (garnishment means taking money directly from a source of income under a court order). Over the years, courts entered judgments confirming what Wayne owed, including a December 2014 judgment for $16,307.50 in unpaid alimony (which the parties agree was later paid off) and a February 2021 judgment for $45,680.68. In February 2023, with the help of a pro bono attorney, Wayne asked the district court to eliminate or reduce his alimony. Among other things, he argued that a Nevada statute, NRS 125.165, barred the court from counting his veterans' disability payments as income when figuring out alimony. He also asked for sanctions under NRCP 11 - a court rule allowing penalties for improper filings - based on statements Jesusa made in her written opposition to his motion. Without holding a hearing, the district court granted both requests in January 2024. It refused to count Wayne's $4,456.22 per month in veterans' disability benefits as income, concluded that Jesusa's net income exceeded Wayne's, terminated the alimony, and made the termination retroactive to August 2022. On its own, the court also went back through a decade of the case's history, decided that the December 2014 order had "overcharged" Wayne by $6,698, credited that amount against his arrears, and imposed $5,000 in sanctions against Jesusa and/or her counsel based on its own review of past filings - not on the four arguments Wayne had actually made in his sanctions motion. The Nevada Court of Appeals reversed. First, it held that NRS 125.165 only forbids courts from attaching, levying, or seizing veterans' disability benefits to satisfy alimony - it does not stop a court from considering those benefits when calculating how much alimony a veteran can afford to pay. Federal law does not forbid such consideration either. If the district court had counted the disability benefits, Wayne's net monthly income would have been over $300 higher than Jesusa's, rather than negative, so the error could have changed the outcome. Second, the appellate court held that the district court should not have gone back and recalculated arrears from the 2014 order on its own. Wayne never asked for that, Jesusa had no notice or chance to respond, and the 2014 judgment was final and could not be reopened under the doctrine of res judicata (claim preclusion) - the rule that a valid, final judgment ends the dispute it resolved. Third, the court vacated the $5,000 sanctions award because the district court never addressed the arguments Wayne actually raised in his NRCP 11 motion and instead sanctioned Jesusa based on its own investigation of her filings over many years, without giving her the required notice and opportunity to respond. Finally, given these circumstances, the Court of Appeals directed that the case be reassigned to a different judge on remand "to ensure fairness in the ongoing proceedings."

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

Kenneth and Kimberly Einiger divorced in October 2014 through a stipulated divorce decree — a divorce settlement the parties agreed to and the court approved. Under that decree, Kenneth took on significant financial obligations to Kimberly, including alimony of $5,000 per month for life (with a 2.5 percent annual increase), her housing costs, various health-related expenses, a monthly credit card allowance, and continued payments on a two-million-dollar life insurance policy naming Kimberly as the sole beneficiary. Kenneth did not fully comply, including with his alimony obligations. Kimberly asked the court to convert the unpaid amounts into a formal money judgment. While that request was pending, Kimberly learned that Kenneth had listed for sale a condominium he had bought after the divorce, and that a sale was pending. She recorded a lis pendens against that condominium. A lis pendens is a public notice that a piece of real estate is tied up in a lawsuit; it warns potential buyers and lenders about the dispute. Because the notice clouded the condo's title, the pending sale collapsed. Kenneth filed an emergency motion to remove (expunge) the lis pendens. The district court denied the motion but said it would consider lifting the notice if Kenneth could show a real, viable pending sale. Kenneth then asked the Court of Appeals for a writ of mandamus — a court order directing a lower court to perform an act the law requires — to force the district court to remove the notice. The Court of Appeals first decided it was appropriate to hear the petition. It explained that an order refusing to expunge a lis pendens cannot ordinarily be appealed directly, and that waiting to appeal at the end of the case would not be an adequate remedy because a lis pendens hurts the property's marketability and can cause substantial hardship to the owner. The court also noted that the district court's willingness to reconsider if Kenneth found a buyer did not fix the immediate harm the notice was causing to the property's title. Turning to the merits, the court held that a lis pendens is only proper when a lawsuit affects the title to or possession of real property. It is not a tool to help collect a money judgment. Here, Kimberly's underlying request was purely about money — reducing unpaid alimony and other financial obligations to a judgment — so it did not justify a lis pendens on Kenneth's separately owned condominium. Kimberly also argued that Kenneth's attempts to sell assets amounted to a fraudulent transfer designed to dodge his obligations. The court acknowledged that a fraudulent-transfer claim can be the kind of action that affects title or possession of real property. But Kimberly had not brought such a claim in her original motion, and her later fraud allegations were too vague — she did not state the circumstances of fraud with the particularity the rules require, and did not identify a specific type of fraud. Because her claims were limited to monetary obligations and she had not adequately alleged fraud, the court concluded the district court had committed a manifest abuse of discretion in refusing to expunge the notice.

This case involves a divorce between Donald and Cheryl Schricker, a couple who dated beginning in 1998, bought and shared property over many years, and married in 2005 before Cheryl filed for divorce in 2019. Their dispute centered on several pieces of real estate and money. The first property was a lakefront property at Lake Almanor in northern California, which the couple bought in 1998 before marrying, and later shared ownership of with friends (the Whittenburgs) through a partnership. The couple's interest in this property became a major point of contention. The district court ordered Donald to buy out Cheryl's share. The second property was a home on Tapadero Trail in Reno, bought in 2010 for $350,000 using money Cheryl inherited from her father. Cheryl said she wanted this to be her own separate property, but Donald's name ended up on the deed. She claimed he added his name secretly; he said she watched the documents being signed. The district court found this home was community property (property belonging to both spouses) rather than Cheryl's separate property. There was also a deed of trust - a document that puts a lien on property to secure a debt - on a separate property Donald owned in Reno, naming Cheryl as beneficiary for $119,000. Cheryl testified she did not know about it until after she filed for divorce and never had a promissory note (the document that normally records the actual loan). Donald said he never borrowed money from her. The district court still found Donald owed Cheryl $119,000 based on the deed of trust because it had never been canceled. During the litigation, Donald did not fully respond to Cheryl's discovery requests and did not file certain tax returns as ordered. As a result, the district court imposed sanctions: he could not present documents he had not disclosed, certain requests for admission were treated as admitted, and the court could draw negative inferences from questions he did not answer. On appeal, the Court of Appeals largely upheld the district court. It held the Nevada court had authority to decide the case, that the Whittenburgs did not have to be added as parties, and that the district court did not abuse its discretion in valuing the Almanor property or in imposing discovery sanctions. It rejected Cheryl's arguments that the Tapadero home should have been her separate property and that Donald committed fraud or breached a fiduciary duty. The one point on which the appellate court reversed involved the value of the Tapadero property. The written decree valued it at $407,000, but the trial transcript showed both parties actually agreed on $704,000. The court concluded the $407,000 figure was not supported by the evidence and appeared to be a clerical error, so it sent the case back to correct the valuation and update the related payment.

Bryce and Maureen White married in 2015. Before the wedding, they signed a prenuptial agreement - a contract made before marriage that sets out how money and property will be handled if the marriage ends. In their agreement, both spouses gave up any right to alimony (ongoing support payments after divorce), and they agreed that any jointly held debts would be split 50/50. In 2023, after Bryce filed for divorce and the couple then decided not to go through with it, they signed a postnuptial agreement (a similar contract made after marriage) that "reaffirms the prenuptial agreement" and again released each other from alimony or support. In 2024, Bryce filed for divorce again. Maureen argued the agreements should not be enforced, claiming among other things that the prenuptial agreement was signed under duress and without full disclosure of Bryce's assets, and she asked for alimony, noting that she had quit her longtime job at Bryce's insistence that he would provide her health insurance. After trial, the district court found the agreements valid and enforceable - it found Bryce had disclosed his assets, Maureen had a chance to have a lawyer review the agreements, and the agreements were not unconscionable. But despite those findings, the court ordered Bryce to pay Maureen $500 per month in spousal support until she turns 65, to cover her medical insurance costs. The court also refused to make Maureen reimburse Bryce for her share of the couple's jointly filed 2023 federal tax bill, and refused to order reimbursement of the health insurance costs Bryce paid for Maureen after their separation. The Court of Appeals reversed the alimony award. It explained that because the district court itself found the agreements valid, and those agreements plainly waived alimony, the court could not order alimony anyway. There was no other written agreement in the record allowing such an award, and both agreements said they could only be amended in writing. The appellate court also reversed the tax ruling: the prenuptial agreement said jointly acquired debt would be split equally, but the district court made no findings about that provision and simply denied Bryce's reimbursement request - even while noting the tax return was jointly filed. The court affirmed one point against Bryce: his request to be reimbursed for Maureen's health insurance costs after their February 2024 separation. He failed to cogently explain how those payments were a "shared debt" under the agreement, so the appellate court left the district court's denial of that request in place. The court declined to decide whether Bryce should be repaid any alimony he may have paid after the decree, noting it was unclear whether he had made any payments, but said he could raise that issue in the district court on remand.

Rochelle Mezzano and John Townley signed a prenuptial agreement before marrying. Among other things, the agreement said that property titled in one spouse's name would be that spouse's separate property, and that the couple intended to "acquire no community property (unless title to property acquired after marriage is specifically taken as community property or joint tenancy property with right of survivorship) during their marriage and that all property acquired during marriage shall be owned by the acquiring party or the person contributing the acquisition funds." The agreement also spelled out specific ways the couple could create community property - property owned jointly by both spouses - such as taking title jointly or designating property as community in a signed writing. Townley filed for divorce in 2019 and initially obtained a default divorce decree, but the Nevada Supreme Court held that decree void because of improper service and sent the case back. On remand, Mezzano filed an answer, a counterclaim (with causes of action including divorce, conversion, breach of fiduciary duty, abuse of process, breach of contract, and breach of good faith and fair dealing), and a crossclaim for conversion. Mezzano then failed to respond to discovery requests, failed to appear for her deposition, and failed to make required disclosures. As a sanction, the district court barred her from "introducing any document she failed to produce in discovery; or as required by NRCP 16.1 or 16.2; and she is precluded from offering any testimony or evidence in support of her affirmative claims and defenses, particularly any claim of damages against Mr. Townley." The court also granted Townley summary judgment - a ruling without trial because no facts were genuinely in dispute - on Mezzano's second through sixth causes of action, and, on its own initiative, on paragraphs 11-13 of her divorce cause of action. At trial over the division of assets and debts, one key dispute involved the Yellowstone properties, two Reno real properties in which Mezzano acquired an interest during the marriage. Mezzano said they were her separate property because the deeds were in her name (along with a third party); Townley testified he did not know the source of the purchase money and that there was no proof community funds were not used. The district court found that "Mezzano did not provide the court clear and convincing evidence to rebut the presumption her interest acquired during the marriage is community property. Therefore, the presumption controls." After dividing the assets, the court ordered Mezzano to pay Townley $740,647 as an equalization payment. The Court of Appeals reversed the ruling on the Yellowstone properties. Even though both sides pointed to competing provisions of the prenuptial agreement - and the district court itself found "the prenuptial agreement is valid and enforceable" - the district court made no findings and offered no discussion of the agreement when deciding whether the community had an interest in those properties; instead it appeared to rely on Nevada's default community property presumption. Because the district court did not analyze the prenuptial agreement on this issue, the Court of Appeals concluded it abused its discretion and sent that portion of the case back for further proceedings. The Court of Appeals rejected Mezzano's other arguments. It held that the discovery sanctions were not "case concluding" because no dismissal occurred and excluding evidence does not amount to a case-concluding discovery sanction; given her failures to appear for deposition and respond to discovery, the sanction was within the district court's discretion. And because the sanction already barred her from introducing evidence supporting any affirmative claim, she could not show she was prejudiced by the court's sua sponte summary judgment on paragraphs 11-13 of her divorce counterclaim, so that ruling was affirmed.

Samarn and Dorothy Reed were married for about 29 years. Before the divorce, Samarn was an executive-level employee at the United States Postal Service (USPS) earning over $200,000 per year. In 2021 he began a relationship with a coworker whom he had promoted and for whom he had advocated for management training and other benefits. When Dorothy learned of the relationship, she filed for divorce; around the same time, Samarn notified USPS's human relations department about the relationship, triggering an internal investigation. In April 2022, the parties entered a stipulated (agreed-upon) divorce decree requiring Samarn to pay alimony - $1,250 per month at first, rising to $2,500 per month for 10 years once his child support obligation for the parties' youngest child ended. The decree contained no provision making the alimony nonmodifiable. In January 2023, USPS concluded its investigation and terminated Samarn's employment, finding he had promoted an applicant with whom he was romantically or sexually involved and knew his conduct violated USPS's rules of employment and ethical guidelines. Samarn appealed to the United States Merit Systems Protection Board, then settled: instead of termination, he accepted a voluntary demotion to a non-executive position paying $110,000 per year and agreed not to seek a promotion at USPS until February 2025. About two weeks later, Samarn asked the district court to terminate his alimony, arguing his demotion cut his monthly income by 45 percent and he could not afford $2,500 per month. He later argued the court should at least reduce alimony to $557.87 per month to equalize the parties' incomes. Dorothy opposed any change, arguing the income reduction stemmed from Samarn's knowing violation of USPS's rules and that he could still afford the payments. After an evidentiary hearing, the district court declined to terminate or substantially modify alimony. Instead, it narrowly restructured the obligation: $2,000 per month from October 1, 2023, through January 31, 2025 (the period before Samarn could again seek a promotion), returning to $2,500 per month thereafter, with the alimony term extended by three months to roughly offset the temporary reduction. The court found that Samarn's income loss was not beyond his control but resulted from his deliberate, willful, and knowing violation of USPS's rules, that he could maintain a nominal budget surplus if he cut unnecessary expenses, and that there was no evidence Dorothy's finances had improved since the divorce. The Nevada Court of Appeals affirmed. It held the district court properly relied on the Nevada Supreme Court's decision in Rosenbaum v. Rosenbaum, which allows courts to consider whether a spouse's reduced earnings result from the spouse's own intentional or purposeful conduct rather than circumstances beyond the spouse's control. The court rejected Samarn's argument that his demotion was involuntary because USPS imposed it, reasoning that Samarn agreed to the settlement and that the changes were precipitated by his own deliberate conduct. It also rejected his argument that considering that conduct improperly penalized him for "bad behavior" during the marriage, distinguishing Rodriguez v. Rodriguez: the district court was concerned not with marital misconduct but with the violation of USPS's employment rules that caused the demotion. Finally, the court held the district court was not required to walk through the NRS 125.150(9) factors - which govern initial alimony awards - and that the court had in substance considered the parties' financial circumstances anyway, so no abuse of discretion occurred.

Valerie Allen and Jashi Mark Allen were married in Jamaica in 2012. Valerie is a United States citizen; Jashi is a Jamaican citizen. According to the opinion, they met while Valerie was on vacation in Jamaica, and for several years Jashi lived in Jamaica while Valerie lived in Florida and visited him. In 2015, Jashi began the immigration process, and Valerie hired an attorney who obtained a United States permanent resident card for Jashi in 2017. Jashi then moved to Utah for trucking school and later relocated to Las Vegas, while Valerie stayed in Florida. The couple separated in 2018, and Jashi filed for divorce in Nevada. Valerie responded and filed a counterclaim, alleging that Jashi had used her for immigration purposes. Because the couple had no minor children, the dispute focused on dividing their property and debts, Valerie's request for spousal support (alimony), and her request to be reimbursed for money she spent to help Jashi immigrate. After a trial in March 2023, the district court entered a divorce decree in April 2023. The court found that the parties' incomes did not support an alimony award and that Valerie had, in any event, given up (abandoned) her alimony claim. The court also found no evidence that Jashi committed fraud in the marriage, and it found that Valerie's requests for reimbursement were not supported by law. The court added that even if Valerie had used her own separate funds to pay for trips and immigration costs, those funds would be treated as gifts to the marital community. The court divided the property: each party kept their own vehicles, personal property, bank accounts, and debts; Valerie kept her mobile home from before the marriage; and Jashi kept his trucking company and tractor truck. To balance things out, the court awarded Valerie a share of the equity in Jashi's tractor truck and a share of community funds used for his truck-driving training, ordering Jashi to pay Valerie $8,750 as an "equalization payment." The court denied Valerie's request for attorney fees. In May 2023, Valerie filed a motion to set aside the divorce decree, claiming that Jashi committed "perjury, slander, libel, obstruction of justice, and ha[d] made false claims" at trial, particularly about his assets. She also asked to have the district court judge removed from the case (recusal). She submitted various exhibits, including vehicle statements, photos, an online report about Jashi, attorney billing statements, medical records, and other documents. The Chief Judge denied the request to disqualify the district court judge in August 2023. The district court then denied the motion to set aside. The court noted that Valerie's own motion acknowledged that her trial counsel had already argued that Jashi inaccurately portrayed his income, so her claims of perjury and other misconduct were merely allegations. The court also found that Valerie had not shown that her new exhibits could not have been produced at the earlier hearing with reasonable diligence, because that evidence was readily accessible at the time. Valerie then appealed. On appeal, the Court of Appeals affirmed. It concluded that the record showed the district court properly divided the community property and calculated the equalization payment, so there was no abuse of discretion. It found that Valerie had not identified specific omitted assets in the lower court and could not raise such arguments for the first time on appeal. On the motion to set aside, the court found that Valerie did not develop a cogent argument explaining why her new evidence could not have been discovered earlier. On alimony, reimbursement, marriage fraud, and attorney fees, the court found that Valerie either failed to develop arguments or failed to address the district court's specific findings, so those challenges were waived.

James and Pamela Gabroy were married for eighteen years. Pamela filed for divorce in September 2019, citing incompatibility. James was an internist (a physician) who had owned and operated his own medical practice for years. He had sold that practice for $800,000 in 2016 but kept working there as an independent contractor for three more years. When his contract was not renewed, he set about reopening the office under his own name. On Pamela's recommendation, James hired a woman named Queenie Manuel around June 2019 to help him with the licensing and credentialing process. Manuel presented herself as an experienced medical credentialist with insurance-industry connections. James agreed to pay her $5,000 a month. The marriage was breaking down at the same time. Over Labor Day weekend in 2019, Pamela said James displayed a revolver during an argument. She obtained a temporary protection order and filed for divorce shortly afterward. She also asked the court for a "joint preliminary injunction" (JPI) — an order that would have frozen both spouses from moving money out of shared accounts while the divorce was pending — but the record shows the court never actually issued one. At an October 2019 hearing, the court ordered the couple to figure out a firm cost to reopen James's practice and to release community funds for that purpose. Four days after that hearing, James wrote Manuel a check for $800,000. He said the money was supposed to go toward licensing, medical equipment, and even a dental practice for low-income patients. But Manuel vanished with the money. James reported her to police, and she was never found. Notably, James did not report this $800,000 loss on his federal tax return, even though he reported other, smaller losses. James later sold his practice to another doctor for $180,000 — far less than the $800,000 he had received for it in 2016 and the same $800,000 he had just handed Manuel. In February 2020, James fell down a flight of stairs, fractured his skull, and injured his back. The court suspended his temporary spousal support because of his health, and the parties later stipulated (formally agreed) to that suspension. James spent eighteen months recovering in an assisted living facility. In October 2022, Pamela amended her divorce complaint to allege that James had committed "marital waste" — that is, wrongly wasting or destroying property belonging to the marriage. James denied it and accused Pamela of the same. After a trial, the district court found that James's $800,000 payment to Manuel was indeed marital waste and ordered him to reimburse Pamela for the community's share of that money. The court also awarded Pamela $1,150 per month in alimony for five years (ending sooner if she died or remarried). On appeal, James argued three things. First, he said the $800,000 payment simply followed the court's own order to release community funds to reopen his practice, so it could not be waste. The Court of Appeals disagreed. The trial court had found James's testimony not credible — questioning why he would pay a $5,000-per-month employee an $800,000 lump sum, and pointing out that he first testified he had written off the loss on his taxes but then admitted on cross-examination that he had not. Because appellate courts do not re-weigh a trial judge's assessment of who is believable, and because there was enough evidence to support the finding, the appeals court upheld the waste finding. James also argued the trial court wrongly relied on a violation of a JPI, since no JPI ever existed. Pamela conceded no JPI was issued but argued the mistake did no harm. The appeals court agreed it was "harmless error" — meaning the mistake would not have changed the result — because the waste finding rested on other, sufficient evidence, and because James made this unusually large payment right after Pamela filed for divorce, when the marriage was already broken. Second, James argued the court did not properly weigh the legally required factors before awarding alimony. The appeals court found the trial court had adequately considered the required factors, made findings on most of them, and treated as neutral or inapplicable the factors on which neither party presented evidence. Even while noting that "many courts would not have ordered alimony" given James's age, health, and reduced finances, the appeals court held the award was supported by the evidence and complied with the statute. Third, James argued the court wrongly excluded evidence about Pamela's alleged offshore bank accounts. The appeals court declined to consider this argument because James did not cite the record or provide adequate legal support.

Christopher and Joy Douglas married in 2015 and had one child together. In June 2022, Christopher filed for divorce and asked to be the child's primary caretaker. Joy asked to be primary caretaker as well and to move the child to Iowa, where she was already living. After holding a hearing, the district court sided with Christopher on the major issues: it gave him primary physical custody, denied Joy's request to move the child to Iowa, denied her request for alimony (spousal support), and denied her request that Christopher pay for the child's travel to Iowa for her parenting time. Both sides had asked the court to make the other pay their attorney fees. Christopher asked for fees under a state law (NRS 18.010(2)(b)) that allows a winning party to recover fees when the other side pursued a claim without reasonable grounds or to harass, and under a local court rule (EDCR 5.219) that allows sanctions for things like filing frivolous positions or dragging out a case to run up costs. The district court found that both parties actually won on some issues and lost on others, and — importantly — that neither party had pursued the case without reasonable grounds or to harass the other, and that neither had taken an unwarranted position or needlessly prolonged the litigation. So the court denied fees under those provisions. The court separately found Joy was entitled to fees under a different divorce-fees statute (NRS 125.040), but that part of the case was not before the appellate court. Christopher appealed the denial of his own fee request. He argued that Joy's positions — asking for custody and relocation without meeting the requirements, asking for alimony while (he said) being deliberately underemployed, and asking him to pay travel costs even though she was the one moving — were frivolous, and that because he won on the big issues he should get his fees. The Court of Appeals disagreed. It explained that whether a claim ultimately loses is not the same as whether it was frivolous or brought without reasonable grounds. Joy had testified at the hearing in support of her requests, and the record did not show her claims lacked any credible support. Because the district court had adequate grounds for its decision, the appellate court could not say the trial judge abused her discretion, and it affirmed (upheld) the denial of Christopher's fees.

Melissa and Paco Horta married in October 2012 and have three minor children. About a decade before the marriage, Paco's father gave him a landscaping business called Silver Lands, Inc. Paco earned a salary from the business and also took money out as company profits. Paco filed for divorce in May 2021, and while the case was pending the district court ordered him to pay temporary spousal support, temporary child support, and some of Melissa's attorney and expert fees. After a trial, the district court issued a divorce decree. It calculated Paco's monthly income, imputed (assigned) an income of $100,000 per year to Melissa based on her earning capacity, awarded her alimony of $3,000 per month for five years and child support of $3,474 per month, and divided the couple's community property. Because of the way it divided property, the court ordered Paco to pay Melissa an "equalization payment" of about $738,000 in monthly installments over ten years. The court declined to award either party additional attorney or expert fees. On appeal, Melissa raised many arguments: that the court miscalculated Paco's income by leaving out a $461,000 "shareholder loan" he took from the business; that the court should not have assumed she could earn $100,000; that it should have awarded more child support and back child support; that Paco wasted $476,000 of marital money on a failed Reno property investment; that she deserved attorney and expert fees; and several other points about parenting time, the family therapist, keeping discovery open on the marital home, and interest on the equalization payment. Paco, in his cross-appeal, argued the court miscalculated the community's interest in Silver Lands. The Court of Appeals rejected almost all of these arguments, finding that the district court acted within its discretion and that its findings were supported by the evidence. On most points, the appeals court explained that it does not re-weigh conflicting evidence or re-judge which witnesses were more believable - that is the trial court's job. The appeals court agreed with Melissa on one narrow point. While the trial court properly found that Melissa had not proven Paco "wasted" the $476,000 Reno investment, the trial court never made findings about whether any of that money still existed. Paco testified he got no return on the investment, but also said the investment home was eventually sold, though he could not recall the sale price. Because some or all of the money might still exist, the appeals court sent the case back (remanded) so the trial court can determine whether any funds remain and, if so, divide them. The court affirmed everything else in the decree.

Lisa and Thomas Gibson divorced in 2003 and then spent roughly two decades fighting in state and federal courts over money Thomas owed Lisa. By 2015, a Nevada district court had consolidated earlier judgments and determined Thomas owed Lisa about $275,000. Before that 2015 judgment was entered, Thomas filed for bankruptcy. Under his repayment plan he paid $2,200 a month for about two years, and roughly $44,000 accumulated for anticipated payments to creditors. His bankruptcy case was later converted from a Chapter 13 (a repayment plan) to a Chapter 7 (a liquidation). Lisa and Thomas then fought over who owned that $44,000. In 2017, the bankruptcy court ordered the money deposited with the Office of the Ex-Officio Constable and allowed Lisa to pursue a writ of garnishment (a court order that lets a creditor collect money held by a third party) against the trustee. Lisa tried to collect the money using writs of garnishment and execution, but multiple delays got in the way — including her own collection attorney filing a lien for attorney fees against the funds. In June 2021, the 2015 judgment expired because Lisa did not file a required renewal affidavit in time. The Nevada Supreme Court upheld that finding of expiration in a 2023 order. Because the judgment had expired, Lisa's attorney filed an interpleader action — a lawsuit that asks a court to decide who among competing claimants actually owns disputed funds. In 2023, the district court concluded Thomas was entitled to the $44,000 because Lisa no longer had a valid judgment to collect on, and ordered the money paid to him. Lisa appealed. The Court of Appeals affirmed. It rejected Lisa's argument that the 2017 bankruptcy order had already decided who owned the money. The court explained that the bankruptcy order only let Lisa file a writ of garnishment; it did not award her the money outright. The later dispute over ownership involved a new situation that arose only after the Nevada Supreme Court confirmed the 2015 judgment had expired — something that could not have been decided back in 2017. The court also rejected Lisa's argument that her 2017 collection efforts extended the life of the judgment. It noted that the Nevada Supreme Court had already decided in the 2023 order that Lisa's collection efforts between 2015 and 2021 did not restart the limitations period, so that question could not be relitigated. The court added that Lisa cited no authority actually supporting the idea that a writ of garnishment extends a judgment's deadline. Finally, because Lisa had no right to the funds, the court found her remaining arguments — about a motion for exemption and about her former attorney's claim to the money — to be moot (no longer presenting a live dispute) and did not address them.

Brian and Bryanna Ho were married for nearly seven years and had two young children. Both filed for divorce in October 2022, and their cases were combined. During the marriage, Bryanna stayed home to care for the children while Brian, a registered nurse, was the primary earner. The couple agreed on joint legal and physical custody of the children, so custody and child support were not part of this appeal. The appeal focused on two money issues: how the court divided the couple's property and how it calculated alimony (support payments from one former spouse to another). The first issue involved a Fidelity retirement account. During the marriage, Brian took out about $24,000 from that account (in two withdrawals of $12,500 and $17,500) and moved the money into the couple's joint Wells Fargo account. He testified he used the money to pay off shared credit card debt, and Bryanna did not dispute that. After the withdrawals, the account was worth roughly $2,486.31. The trial judge, however, found there was "no proof" of where the money went, called the withdrawals "unilateral and unsupported," and decided to treat the account as though it still held its pre-withdrawal value of $30,000 when dividing the property. To keep the split even, the court then shifted $10,686 of the marital home's equity from Brian to Bryanna. Notably, the same court also expressly found that neither spouse had committed "marital waste." The Court of Appeals held this was contradictory. If the court found no waste, then the withdrawn money was presumed spent for the benefit of the marriage (here, to pay off community debt). A community asset must be valued as of the date the divorce decree is entered - which was about $2,486.31, not the pre-withdrawal $30,000. By valuing the account at $30,000 without finding waste, the court effectively penalized Brian for waste it had said did not exist. The appellate court reversed this part and sent it back for a proper valuation and recalculation of the property division. The second issue was alimony. Bryanna asked for alimony so she could finish her education, explaining she had stayed home by agreement during the marriage. The trial court awarded her $1,650 per month for three years. In doing so, it decided Brian was capable of earning $12,680 per month - the monthly average from his 2022 tax return - even though his most recent 2023 financial disclosure showed a much lower gross monthly income of $7,271.16 plus small, occasional overtime. The court found Brian's explanation for why he stopped working overtime (the end of pandemic bonuses, more nurses hired, and his new custody schedule) not credible, and concluded he was reducing his income to lower his support obligations. The Court of Appeals agreed the trial court could award alimony and had properly analyzed the required statutory factors. But it found the *amount* was not supported by substantial evidence. The court had effectively added about $5,000 per month of "imputed" (assumed) income to Brian's figure without identifying how much of that was supposed to be overtime versus regular pay, and without evidence showing Brian could actually work that much overtime given the end of pandemic conditions and his new parenting duties. The appellate court also pointed out a factual mistake: the trial court described Brian's parenting time as a flexible "visitation" schedule, when in fact he had been awarded joint physical custody, which limited his availability to pick up extra shifts. Because the trial court did not properly account for Brian's changed circumstances or his actual ability to pay, the appellate court reversed the alimony amount and sent it back for reconsideration. Because it reversed the underlying rulings, the court also reversed the order requiring Brian to pay $4,245 of Bryanna's attorney fees.

Reginald and Billie Buck married in 2010 and acquired a number of real estate holdings during their marriage. When they divorced, the trial court had to decide which properties were "community property" (jointly owned by both spouses and split equally on divorce) and which were the "separate property" of one spouse. The trial court ruled that three properties - referred to in the opinion as Tomnitz, Roping 1, and Roping 2 - were community property to be divided equally. For several other properties, the court applied a Nevada formula (from a case called Malmquist) that mathematically apportions the community's and the separate owner's shares when separate-property real estate has been improved or paid down with marital funds. The court also awarded Billie her entire 401(k) retirement account and denied spousal support to either spouse. Both spouses appealed. Reginald argued that he had put his own pre-marital money into Tomnitz, Roping 1, and Roping 2 and should get a separate-property share of each. The Nevada Supreme Court rejected this, explaining that property bought during marriage is presumed to belong to the community, and that Reginald's separate funds had been so thoroughly mixed into the couple's joint bank accounts that he could not trace them out. Reginald also disputed the math on three other properties (Ocean Harbor, Horizon, and Durango); the Supreme Court found the trial court's calculations supported by the evidence. On Reginald's challenge to the 401(k) award, the Supreme Court agreed with the trial court that Reginald had spent down community funds and his own retirement account to support a new family before the divorce was final. Nevada law allows a judge to make an unequal property split when one spouse has wasted marital assets, and the Court held that rule was properly applied here. On Billie's cross-appeal, she argued that some properties Reginald had been given by quitclaim deed during the marriage should still be treated as community property. The Court explained that under Nevada law, when one spouse signs a deed transferring property to the other spouse, the law presumes a gift, and only clear and convincing evidence can defeat that presumption. The trial court found no such evidence here. Billie also argued she should get spousal support, but the Court held that because both spouses had similar earning capacity and could each cover their own needs, denying support was within the trial court's discretion. Finally, Billie wanted the trial court to use new property appraisals done after the divorce decree was entered. The Court explained that under Nevada law, the marriage and the community both end when the written divorce decree is issued, so the values fixed at that date control. The Supreme Court affirmed the trial court in all respects.

Cherelyn and Timothy Harris-Bey had been married, divorced, and then remarried in December 2019. In June 2021, Cherelyn filed for divorce. The main disputes were how to divide the couple's property and whether Cherelyn should receive alimony (financial support paid by one former spouse to the other). After a trial, the district court entered a divorce decree in May 2023 that gave Timothy the couple's home, let each person keep the bank accounts in his or her own name, and ordered Timothy to pay Cherelyn $350 per month in alimony for six months. Cherelyn appealed. Cherelyn's first argument was that the court should not have given Timothy the marital home because his written response in the case (his counterclaim) had actually proposed giving the home to her. The appeals court explained that this proposed division no longer controlled the case, both because Cherelyn had denied that part of Timothy's counterclaim in her reply and because Timothy later said, about a year before trial, that he was no longer willing to give up the home. As a result, the case moved forward on general requests for relief from both sides, which the court said were enough to let the district court divide the property according to each person's interests. On the home itself, the appeals court agreed that Timothy had bought the house as his separate property in June 2019, between the couple's two marriages, and that the district court was entitled to believe his testimony over Cherelyn's (the district court found Cherelyn was not a credible witness, and appeals courts do not re-weigh credibility). But there was a problem: Timothy used money he earned during the second marriage (which counts as community property, meaning property owned jointly by the couple) to pay the mortgage. Under Nevada law, when community money is used to pay for separate property, the community earns a proportional ownership share. The district court never applied the required legal formula (from a case called *Malmquist*) to figure out that share, and it did not make adequate findings to justify giving the whole house to Timothy. So the appeals court reversed that part of the decree and sent it back for the district court to determine each party's interest in the home. Cherelyn also argued that the court wrongly failed to divide certain accounts Timothy had not disclosed: a cryptocurrency account, a thrift savings plan (TSP) account, and an account tied to a Mastercard. The appeals court upheld the district court here, because the district court found Timothy's explanations credible - that he never funded the cryptocurrency account, that he had emptied the TSP account (which had a zero balance) before the remarriage, and that he did not open or know about the Mastercard account. Because testimony counts as evidence and the appeals court does not reassess credibility, this part of the decree was affirmed. The appeals court reached a different result on a Navy Federal Credit Union (NFCU) bank account in Timothy's name. Both Timothy's employment earnings and Cherelyn's unemployment benefits were deposited into that account during the second marriage, making those funds community property. Once community funds were mixed into the account, the law presumes the entire account is community property, and Timothy offered nothing to rebut that. The district court gave the whole account to Timothy without stating any compelling reason for an unequal split, so the appeals court reversed that part and sent it back for a proper division. The court noted this conclusion was further supported by Timothy's failure to respond to Cherelyn's argument on this point in his brief. The court also directed the district court on remand to address a related question about a 2020 federal tax refund allegedly deposited into that account and a possible community debt from an overpayment of unemployment benefits. On alimony, the appeals court affirmed. The district court had made extensive findings under the statutory factors and concluded that $350 per month for six months was appropriate given the financial disparity between the parties, the short-term nature of the second marriage, and Cherelyn's failure to maintain viable employment even though she was able to work. Cherelyn's arguments failed either because she had not raised them in the trial court or because she had not shown the findings lacked support. Finally, the appeals court rejected Cherelyn's claim of judicial bias. Judges are presumed unbiased, and Cherelyn did not show the judge relied on outside knowledge or displayed the kind of deep-seated antagonism that would make a fair judgment impossible. The court therefore declined to order reassignment.

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.

Alan and Julie divorced in 2019. As part of the divorce, the court divided their property, awarded Julie alimony (spousal support), and made findings about a surplus of tax credits the IRS was holding that belonged to the couple. The alimony award started at $2,500 per month for seven years, then dropped to $1 per month for ten more years. The court also ordered Alan to give Julie yearly information about all of his sources of income. Later, Julie went back to court, saying Alan had not given her the income information he was ordered to provide, had not divided the tax credits, and had failed to make his alimony payments. During the fact-gathering (discovery) part of the case, documents surfaced showing Alan's income had grown substantially — a loan application listing monthly income over $20,000, and a 2021 tax form showing more than $254,000 in self-employment income plus another $115,662 in a separate category. Julie also produced Alan's 2018 tax return, which showed the IRS held a tax credit of $67,557, meaning her half would be $33,778.50. The court repeatedly ordered Alan to produce his recent tax returns, but he did not. Because he refused to disclose this information, the court granted Julie's request for sanctions: it barred Alan from using evidence at the upcoming hearing that he had not turned over, and said it would draw an "adverse inference" (an assumption against him) about the information he withheld. The court also warned Alan that he was required to appear at the hearing. At the June 23, 2023 hearing, Julie testified, but Alan did not show up. Because Alan failed to produce his tax returns for 2019 through 2022, the court found he had not met his burden to show he could not afford to pay alimony. The court raised his alimony to $3,500 per month for the remaining 161 months. Then, pointing to Alan's repeated failures to follow orders and to pay, the court decided to convert those monthly payments into a single lump sum of $563,000, reasoning this was necessary to make sure Julie actually received her support. The court also awarded Julie her $33,778.50 share of the tax credits, found Alan owed $30,500 in back alimony, and held him in contempt. On appeal, Alan argued the court went too far and essentially rewrote the divorce decree, that it should not have believed Julie's testimony, and that the alimony would extend into his retirement years and be more than he could afford. He also argued there were actually zero tax credits left, and that the court broke a local rule by adopting Julie's proposed orders without letting him review them first. The Court of Appeals affirmed. A central reason: Alan never provided the appeals court with a transcript of the evidentiary hearing, even though he was told he needed to. Without the transcript, the court explained, it had to presume the missing record supported the district court's decisions, and it could not meaningfully review his challenges to the factual findings. The court also emphasized that it does not re-weigh evidence or second-guess a trial court's decisions about which witnesses to believe. On the local-rule issue, the court agreed that if the district court adopted Julie's proposed orders without giving Alan a chance to respond, that was error — but it found the error harmless because Alan had not shown that a different result would have been reached without it.

This is a divorce case between Irina and Douglas Ansell. Before marrying in 2012, the couple signed a prenuptial agreement—a contract that spells out, in advance, how property will be treated as "separate" (belonging to one spouse) or "community" (shared) and how it will be divided if they divorce. Doug's separate property included several businesses (called the Ansell companies) and real estate. The couple married, had one child, and Irina filed for divorce in October 2015. The case took years. The district court split it into three separate trials: one on child custody, one on whether the prenuptial agreement was valid (the court ruled it was and that it would govern the financial issues), and a third on how to divide the couple's assets. That third trial happened in December 2017, but the court did not actually issue the divorce decree until February 2021—more than three years later. The decree gave Irina some alimony, child support, and an "equalization payment" (a lump sum meant to balance out the division of property) of $972,471. After the decree, both sides filed motions. Doug asked the court to give him credit for personal income tax payments he had made, arguing those taxes were a shared community obligation, and he asked for attorney fees. The court agreed with Doug: it credited half his tax payments against what he owed Irina and awarded him attorney fees, which together wiped out his entire equalization payment obligation—reducing Irina's award to essentially zero. The court denied Irina's own late-filed motion as untimely. Irina then appealed. Before reaching the substance, the court had to deal with a technical problem: Irina's notice of appeal named only the November 2021 post-trial order, not the February 2021 decree. Doug argued this meant she could not challenge the decree at all. The court disagreed. It explained that Nevada strongly prefers deciding appeals on their merits rather than on technicalities, that Irina's intent to appeal the decree could be reasonably inferred from the circumstances, and that Doug was not misled or harmed. The court did, however, remind Irina's counsel to name every order they intend to appeal in the future. On the substance, the court reached mixed results. It rejected Irina's argument that the district court was required to accept a particular expert's much higher valuation of Doug's businesses (about $9.9 million in appreciation); the court found she had not properly preserved that argument, had not cited the record to support it, and had not cogently explained why the court was bound to adopt that valuation. But the court agreed with Irina on several other points. It held that the district court wrongly refused to give Irina any share of the increase in value of Doug's real estate. Under the plain language of the prenuptial agreement, Irina automatically got a community property interest in the appreciation of Doug's separate property—whether or not she had put personal time or effort into managing the properties. The court also held that the district court wrongly assigned certain of Doug's loans and debts to the community, because the prenuptial agreement said debts became joint only if both spouses signed a document agreeing to be jointly indebted, and no such document existed. The court further held that the district court failed to consider whether Irina received any benefit from Doug's income after the couple separated—income that, under Nevada law, is presumed to remain community property until the divorce is final. On the tax issue, the court found the prenuptial agreement was ambiguous about whether Irina could be liable for tax debt incurred during the marriage without a signed joint-indebtedness document, and the district court had not made the factual findings about the parties' intent needed to resolve that ambiguity. Because of that, and because it was unclear whether Irina received any of Doug's income during the relevant period, the court reversed the tax ruling and sent it back. Finally, because the court reversed parts of the decree, the attorney fee awards no longer rested on solid ground—it was no longer clear that Doug was the "prevailing party" or that he had beaten his settlement offer—so the court vacated (cancelled) the fee awards. The case returns to the district court to redo the affected portions.

Jay and Debra Grybowski were married for 26 years. During the marriage, Jay was the primary wage earner while Debra was out of the work force for over 18 years due to a medical illness. In 2014, Debra filed for divorce, and the district court entered a decree of divorce in December 2016. The divorce decree and later orders created several financial obligations for Jay. Among them: $1,800 per month in alimony, half of the community property share of funds from Jay's wrongful termination settlement with Hewlett Packard (HP), an equalization payment of $114,740.59 (partly to offset a finding of "marital waste"), and three separate attorney-fees judgments. Two of those attorney-fees judgments each required $1,000 per month in payments. Over the following years, the case moved through multiple judges and several rounds of proceedings, including a finding in 2018 that Jay was in contempt for willfully failing to pay alimony and attorney fees during three months in 2017, even though the court found he had the ability to pay. A key dispute arose over exactly how much Jay owed each month. A February 2020 order stated that Jay should pay a total of $2,800 per month ($1,800 alimony plus $1,000 toward attorney fees). Debra asked the court to reconsider, arguing this was a computation error that accidentally changed prior orders, which had actually required $1,800 in alimony plus $2,000 in attorney-fee payments (two separate $1,000 obligations). After Judge Nadin Cutter took over the case and held an evidentiary hearing, the court concluded in August 2022 that the $2,800 figure was a clerical error and that the correct total was $3,800 per month. The court also determined that Jay owed a large outstanding balance and set up a plan requiring him to pay $10,000 per year for 13 years to satisfy three additional judgments (Debra's HP settlement share, the equalization payment, and the third attorney-fees judgment). The court found Jay had the financial ability to make these payments. In weighing the evidence, the court found Debra more credible because she provided more proof of payments than Jay did. Jay asked the court to reconsider that August 2022 decision, and the court denied his request in December 2022, confirming the $3,800 monthly amount. Jay then appealed. On appeal, the Court of Appeals rejected Jay's arguments. The court explained that there is a difference between "modifying" a divorce order (changing the parties' substantive rights, which a court generally cannot do to a divorce decree except as allowed by rule or statute) and "clarifying" or enforcing an order (defining rights already awarded, which a court retains inherent authority to do). The court concluded the district court had merely clarified and enforced the existing judgments, not modified them. It also held the district court had discretion to set up a payment schedule, that the record supported the $3,800 monthly figure, and that it would not reweigh the district court's factual findings or its assessment of which party was more credible. The court therefore affirmed. It also declined to sanction Jay, because it did not appear his appeal was brought solely to cause delay.

Michelle and Kerry Faughnan married in 2008. In 2021, Michelle filed for divorce, asking the court to divide the couple's shared property and to award her alimony (ongoing support payments from one spouse to another after divorce). Kerry responded and filed his own claims. The court set deadlines: discovery (the pretrial process of gathering evidence and information from the other side) would close on March 23, 2022, and trial would begin later in April 2022. On March 25, 2022 - after the discovery deadline had passed - Michelle asked the court to extend discovery and push back the trial. She said Kerry hadn't fully disclosed information about assets, his income, and his criminal charges, and that she and her attorney both had health problems that had slowed them down. The court denied her request. It found the request was filed too late under a local court rule, that she hadn't shown "excusable neglect" for the delay, that she hadn't included the required list of completed and remaining discovery, and that she hadn't shown good cause to delay the trial. Before trial, the parties settled their disagreements. The court entered a divorce decree that included their agreements on dividing property and on alimony. Under the agreement, Kerry would make Michelle's $1,319 monthly car payment until the car was paid off and also pay her $1,350 per month during that period; once the car was paid off, he would pay her $2,700 per month until April 2027, when the alimony obligation would end. The alimony would also end if Michelle remarried or if either party died. The parties agreed the alimony was otherwise non-modifiable - meaning it could not be changed later. Michelle then asked the court to set aside the decree under a rule (NRCP 60(b)(1)) that lets courts undo a judgment because of "mistake, inadvertence, surprise, or excusable neglect." She argued the alimony wasn't enough to support her, that the earlier denial of her discovery-extension request was a mistake, and that she had been effectively forced into settling. She also filed a motion claiming an asset had been left out of the decree. The district court denied both motions. On appeal, the Court of Appeals affirmed. It held that the district court had acted within its discretion in denying the discovery extension and continuance, noting that Michelle filed late, did not explain her delay, and that her own attorney admitted he had not reviewed the discovery materials in time - showing a lack of diligence. Because the underlying discovery ruling was not erroneous and did not deny Michelle a fair chance to present her case, it was not a "mistake" that justified undoing the decree. On alimony, the court noted the parties had agreed the award was non-modifiable, and that even if it could be changed, Michelle had not shown the changed circumstances required to modify it. Finally, the court held Michelle waived any challenge to the omitted-asset ruling because she offered no argument about it on appeal. The court also declined Kerry's request to sanction Michelle for filing a supposedly frivolous appeal.

Donte and Carmen Lofton married in 2012. In 2020, Carmen filed for divorce and asked the court to divide their shared property and award her alimony (spousal support - money one spouse pays the other after divorce). After a trial, the district court entered a divorce decree that divided the property and ordered Donte to pay Carmen $750 per month in alimony for 36 months. A separate order entered on August 11, 2022, resolving a dispute over insurance policies, was the final order in the divorce. In 2022, Donte asked the court to lower his alimony, saying his financial situation had changed. He pointed to periods of unemployment, higher mortgage payments, new financial responsibility for his grandchild and disabled adult son, and large expenses from unrelated criminal court matters, including attorney bills for a charge that could carry a life sentence. He submitted tax returns and financial disclosure forms. His 2021 return showed annual income of $27,405, but his updated disclosures showed rising income - one amended form stated he could earn $142,318.20 if he worked a full year. Carmen opposed the change, arguing that Donte's line of work normally involves brief gaps between projects, that he would likely be rehired soon, and that he actually earned more in 2022 than in 2021. She also asked the court to order Donte to explain why he should not be held in contempt for not paying the required alimony. After a hearing, the district court found that Donte's income had increased substantially - from about $27,000 in 2021 to an annual income of about $142,000 - and concluded he had not shown that lowering his alimony was warranted. The court later entered an order awarding Carmen $6,550 in alimony arrears plus $413.95 in interest, and turned that into a judgment. On appeal, Donte first tried to overturn the original divorce decree's alimony and attorney-fee award. The appeals court said it could not consider that challenge because Donte did not file his appeal within the deadline after the final order in the divorce. When an appeal is filed too late, the court has no power (jurisdiction) to hear it, so that portion of the appeal was dismissed. Donte next argued the court was wrong to deny his request to lower the alimony, saying it misjudged his income and did not properly weigh his other obligations. The appeals court explained that it does not re-decide factual questions when the lower court's decision is supported by adequate evidence. A key problem for Donte was that, although he requested a hearing transcript, he never provided the appeals court with a copy of it. Because the court had no transcript of the hearing where the income evidence and arguments were presented, it presumed the missing transcript supported the district court's findings and could not meaningfully review his challenge. On that basis, the court concluded Donte had not shown the district court abused its discretion. Finally, to the extent Donte tried to challenge the order turning the arrears into a judgment, the court held he made no actual argument about that decision, so he waived (gave up) any challenge to it. The court affirmed the denial of the modification motion and the arrears judgment.

Lisa and Chris Cunning married in 2000 and had two children. During the marriage, Lisa homeschooled the children and managed the home while Chris, a commercial real estate agent and licensed stockbroker, handled the family's finances and investments. Lisa alleged that Chris began trading in futures without her knowledge in 2013 and by 2018 had lost all of the couple's shared savings. Both spouses, however, had inherited separate money kept in accounts that stayed intact. Lisa filed for divorce in January 2020. Among other things, she asked the court to award her alimony (ongoing financial support), divide the couple's property and debts, and reimburse her for "marital waste" — a claim that Chris had wasted, hidden, or squandered money that belonged to both of them. She pursued extensive investigation, hiring a forensic accountant, subpoenaing more than 27 financial institutions, and generating over 10,000 pages of records. Because Lisa had no income, the court ordered Chris to pay her $2,000 a month in temporary support during the divorce and to keep paying the shared household expenses. But the court noted that because the couple's shared assets were nearly gone, if Chris was using his own separate money to cover shared expenses, whether he should be paid back would be decided at trial. Later, after the couple's minor child finished high school, the court told Lisa to look for a job to become financially independent. At trial, Lisa did not call her forensic accounting expert and did not use the financial records she had gathered to support her marital waste claim. She told the court she was no longer pursuing that claim and instead tried to enforce what she said was an oral promise by Chris to give her his interest in the family home. Her only evidence of this promise was her own testimony. Chris called a rebuttal expert who testified about the time and cost of responding to Lisa's discovery requests. The court divided the property and debts, reimbursed Chris for the separate money he had contributed, and awarded Lisa alimony of $3,000 a month for 84 months (seven years). It also decided that attorney fees were appropriate for both sides. In later orders, the court required Lisa to pay her own lawyers' liens out of her share of the property and to pay part of Chris's attorney and expert fees because her marital waste claim was, in the court's view, pursued without reasonable grounds. After all the additions and subtractions, Chris received $751,190.75 and Lisa received $322,377.16, with more to come once the family home sold. The Court of Appeals upheld nearly all of the district court's decisions. It agreed that the community debts were properly divided equally, that Chris was entitled to be reimbursed for separate money he spent covering shared expenses (including the temporary support paid to Lisa), that the alimony award was supported by the evidence, and that requiring Lisa to pay attorney fees was within the court's discretion. The appeals court declined to revisit the marital waste and hidden asset claims because Lisa had told the trial court she was dropping them. The one place the appeals court sided with Lisa involved two 2000 Honda XR motorcycles. The court had given Chris the physical motorcycles as his separate property and also awarded him an extra $3,500 as reimbursement for those same motorcycles. Because Chris received both the items themselves and money for them — with no evidence the items had been sold or lost to pay shared expenses — the appeals court reversed that $3,500 add-on and restored the original $115,620 reimbursement figure from the initial decree.

This case arose from a divorce between Joseph Raul Garcia Rodriguez and Zoila Leon-Yanez. Their disputes centered on how to divide their shared property, how much Garcia Rodriguez should pay in child support and alimony (spousal support), and whether he should pay Leon-Yanez's attorney fees. Early in the case, Garcia Rodriguez was representing himself. He did not file a required document (a pre-trial memorandum) and did not show up to a court date called "calendar call." Because of that, the court treated him as being in "default" - meaning it proceeded without his participation - and held a hearing where only Leon-Yanez testified. Based on her testimony, the court entered a divorce decree that gave Leon-Yanez a piece of real estate (a corner building with two units, one on Pine Street and one on Ashton Street, called the "P&A Street property"), ordered Garcia Rodriguez to pay $1,500 per month in alimony for 10 years, set his child support at $1,128 per month, and required him to pay $5,500 of Leon-Yanez's attorney fees. Garcia Rodriguez then hired a lawyer and asked the court to undo the decree. He argued he did not understand the court's procedural requirements, that the support amounts did not match his actual income, that the property was divided unequally, and that the attorney fee award was not properly justified. He also raised a concern that a second property - one on Division Street - had accidentally been swept into the award to Leon-Yanez. The district court refused to set the decree aside but treated part of his request as a motion to change (modify) his support obligations. It refused to lower child support, saying a financial disclosure form (FDF) he filed in June 2022 was missing a page. But it did lower alimony to $700 per month. Notably, Garcia Rodriguez had filed a corrected, complete FDF in July 2022, and the district court never discussed that updated form when deciding these issues. On appeal, the Court of Appeals sorted out the property question first. It concluded that, reading the decree together with the record, Leon-Yanez received only the P&A Street property (not two separate properties), and that the court's later order effectively awarded the Division Street property to Garcia Rodriguez. That produced a one-for-one split of the two real properties - exactly the equal division Garcia Rodriguez said was required. Because he did not explain how he was harmed by the rest of the property allocation, the court affirmed the property decisions. On child support, the appeals court found the district court made a mistake by refusing to consider the more recent July 2022 FDF, which showed his income had dropped. On alimony, the court found the same mistake: the district court relied on older figures and an assumption that Garcia Rodriguez still received rental income, without considering the July 2022 form showing he no longer did. On attorney fees, the court held that the district court failed to analyze the required factors (known as the Brunzell factors) before ordering him to pay $5,500. The result: the appeals court affirmed the property division but reversed the child support, alimony, and attorney fee rulings and sent the case back to the district court to reconsider those issues in light of the July 2022 amended FDF and the required legal factors.

This case grows out of a divorce that was finalized in 2015. When Brian and Rourong Yu divorced, the court divided the property they had accumulated during the marriage (called "community property"). In the years that followed, the two continued to fight in court over how that property was split and whether various sums of money had been properly accounted for. Earlier in the dispute, the district court found that Brian had removed $176,000 from community accounts and ordered him to pay Rourong $88,000 from his own separate property. An earlier appeal to this same court affirmed that decision. Later, Rourong asked the court to enforce the decree and the follow-up orders, and the district court held an evidentiary hearing (a proceeding where both sides testify and present evidence). After that hearing, the court found that Brian had hidden money in a Synchrony Bank account and a Gain Capital account, awarded Rourong $34,579 for her share of the value of Brian's accrued sick and vacation hours, and ordered Brian to pay her $19,989 he still owed. Brian appealed. He raised several arguments. First, he tried to attack the original 2015 divorce decree itself—claiming an investment account should not have been treated as community property, that it was improper for Rourong's lawyer to draft the decree, and that Rourong added information to the written decree without his approval. The Court of Appeals said it could not consider these arguments because Brian never filed a timely appeal from the decree. Under the appellate rules, a notice of appeal must be filed within 30 days, and because he missed that deadline, the court had no power ("jurisdiction") to review the decree. Second, Brian challenged the findings from the evidentiary hearing—the concealed accounts, the calculation of his sick and vacation leave, and the $19,989 he acknowledged owing but argued should be reduced by money he had earlier given Rourong for her attorney. The problem, the court explained, is that Brian never provided the appellate court with a written transcript of the evidentiary hearing. When someone appeals and challenges what happened at a hearing, it is that person's responsibility to make sure the reviewing court has the transcript. Brian had requested transcripts and the court reporter delivered them, but Brian did not file them with the court. Because the court could not see what evidence was presented, it followed a long-standing rule: when the record is missing, the court presumes the missing material supports the lower court's decision. On that basis, the court concluded the district court's findings were adequately supported and affirmed them. Finally, Brian argued the district court should not have adopted the written order that Rourong's side proposed. Because Brian had not shown that the order contained unsupported findings or legal errors, the court rejected this argument too. The court also noted that some motions Brian had filed below were never decided and remain pending, so any arguments about those motions were not properly before the appellate court.