Nevada family-law case summaries

Bryce Wolfe and Taylor Mannion (now Taylor Clayton) share a young daughter, E.W., born in March 2022. According to the opinion, E.W. is nearly blind, has a growth-hormone deficiency, and has several developmental delays. In 2023, the parents mediated an agreement to share joint legal and joint physical custody, and the district court adopted that agreement, setting up a schedule where E.W. rotated between her parents every two or three days. Things changed when Taylor became engaged to a military servicemember being transferred to a base near San Diego, California. In February 2024, Taylor asked the court for primary physical custody and permission to move to California with E.W. Bryce opposed that request and asked for primary physical custody himself. By the time of the hearing, Taylor had married. At a January 2025 evidentiary hearing, both parents testified. Even though Taylor had asked for primary custody, she said she would be open to continuing to share custody, suggesting a two-weeks-on, two-weeks-off arrangement. She testified that E.W. needed regular specialist visits and twice-weekly therapy, but said she was not worried about continuity of care as long as E.W. had insurance and providers in both states. Bryce disagreed that a long-distance shared arrangement was in E.W.'s best interest, emphasizing E.W.'s need for stability, the difficulty of long car trips, and the importance of consistent therapists. At one point, Bryce told the court "it would be up to what you decide" because he "do[es]n't set custody . . . for a living." In March 2025, the district court denied both parents' requests for primary physical custody and effectively denied Taylor's request to relocate. The court found that Taylor had a good-faith reason for the move but had not shown that relocation was in E.W.'s best interest or offered an actual advantage. The court found that all of the best-interest factors were either neutral or did not apply, and concluded that both parents were fully capable of caring for E.W. The court kept joint physical custody in place, but — to address Bryce's concern about frequent travel — ordered a one-month-on, one-month-off schedule instead of the two-week rotation Taylor had suggested. On child support, the court kept the baseline obligation at $0 because the parents' incomes were similar, but ordered Taylor to pay Bryce $100 per month for transportation costs tied to her decision to relocate. Bryce asked the court to reconsider its custody and parenting-time decisions (but did not separately challenge the $100 transportation award), and the court denied that request. He then appealed. The Court of Appeals rejected each of Bryce's arguments. It held that his due process rights were not violated, because Nevada's custody statutes put him on notice that joint physical custody was a possible outcome once custody was before the court, and he had a chance to be heard on the issue. It held that the court did not abuse its discretion in finding a substantial change in circumstances (relying on a prior Nevada Supreme Court case involving a relocating military spouse) or in finding that joint custody with a monthly schedule served E.W.'s best interest — noting that much of Bryce's argument amounted to asking the appellate court to reweigh the evidence, which it does not do. Finally, it held that the court properly handled the $100 transportation award as part of the overall child support determination and that Bryce had not built a record showing the amount was inadequate. The court affirmed.

Anthony Ibanez and Patamawadee Chaisawang were never married but have a child together, born in September 2021. In June 2023, Ibanez filed a court complaint asking for sole legal and primary physical custody after Chaisawang moved from Nevada to California with the child. He argued that Chaisawang had taken the child without his permission—an "abduction"—and asked that the child be returned to Nevada. Chaisawang responded, denied taking the child improperly, and formally asked the court for permission to relocate to California with the child. After a trial where both parents testified and submitted evidence—including text messages between them and a statement Ibanez gave to police the day after Chaisawang moved—the district court gave the parents joint legal custody, gave Chaisawang primary physical custody, and allowed her to relocate to California. The court also set a child support amount. Ibanez then filed a motion asking the court to reconsider its custody decision, arguing the court used the wrong legal standard when evaluating whether an abduction occurred and improperly relied on things that happened after the move. The court denied that motion and later issued a separate order setting Ibanez's monthly child support obligation at $959.33, based on a gross monthly income of $9,116.67 and a $250 reduction for transportation costs. On appeal, Ibanez raised several arguments. First, he said the court used a stricter standard of proof ("clear and convincing evidence") when deciding whether an abduction happened, when it should have used the lower "preponderance of the evidence" standard (meaning "more likely than not"). The appeals court disagreed. It explained that while the trial court had referenced a subsection dealing with a special legal presumption against parents who commit abduction, the court also analyzed the abduction question under the ordinary best-interest factor and later clarified in writing that it had applied the "more likely than not" standard. The appeals court found Ibanez did not show the wrong standard was used. Second, Ibanez argued that the evidence proved Chaisawang abducted the child and that recognizing this would have shifted other factors in his favor. The appeals court noted that the trial court repeatedly declined to find an abduction, and that its findings—based on testimony and text messages showing Chaisawang had tried to reach a custody agreement while Ibanez refused to compromise—were supported by adequate evidence. The court emphasized that weighing evidence and judging witnesses' credibility is the trial court's job, and an appeals court does not re-weigh that evidence. Third, Ibanez challenged the decision letting Chaisawang relocate to California, saying the court improperly relied on benefits that only existed because of the move (like a California school). The appeals court explained that when there is no prior custody order, a parent still needs court permission to move a child out of state, and the court must decide what is in the child's best interest. The trial court found a "sensible, good faith reason for the move"—a better school with services for the child's speech delay, nearby family, and Chaisawang's flexible remote work. The trial court also clarified that it relied on forward-looking, prospective benefits rather than benefits that had already accrued from the move. Fourth, Ibanez challenged the child support calculation, saying the court overstated his income. The appeals court found the income figure was supported by evidence: his own disclosure form showing $6,516.67, plus regular monthly transfers of at least $1,500 from his grandmother, plus $1,100 in rental income. The court also noted Ibanez received the $250 transportation reduction he had requested. Finally, Ibanez argued the court wrongly denied him attorney fees because Chaisawang caused the litigation by abducting the child. Because the appeals court had already upheld the finding that there was no abduction and no abuse of discretion in the custody decision, it found no abuse of discretion in denying attorney fees. The court affirmed all the district court's orders.

This case involves a father, Terrell Avalon Lancaster, who was ordered to pay child support for his minor child with Kenita Lamar Bauerle. The Clark County District Attorney's Family Support Division (a government office that handles child support enforcement) started the process in September 2022. Lancaster signed a document accepting service of the paperwork in November 2022, and later signed an "order upon consent" - a document in which he acknowledged he was the child's father and agreed to pay child support and past-due support (arrears). That order was formally entered by the court in December 2022. In July 2025, DAFS asked the court to enforce the order, claiming Lancaster had not been paying. Lancaster fought back, asking the court to throw out (set aside) the order he had signed. He gave several reasons: that he was pressured into signing because a DAFS representative allegedly threatened him with arrest and loss of his driver's license; that the order was the product of a "bait and switch"; and that he was tricked into signing the acceptance of service and was never actually given the paperwork, which he argued meant the court never had proper authority (jurisdiction) over him. A hearing master (an official who hears the matter and makes a recommendation to the judge) recommended denying Lancaster's request. The hearing master found that some of Lancaster's arguments were filed too late - beyond the six-month deadline that applies to certain requests to undo a judgment - and that Lancaster had accepted service and was properly served. The hearing master also found that Lancaster gave up his right to object to the court's authority over him because he did not raise that objection in a timely way. The district court agreed with the hearing master, and Lancaster appealed. The Court of Appeals affirmed. It concluded that the district court has authority over child support cases, and that Lancaster did not show otherwise. On the question of authority over him personally, the court found the hearing master's conclusion - that Lancaster accepted service and was properly served - was supported by adequate evidence. The court also noted that Lancaster waived (gave up) his ability to challenge that authority by not raising it in a timely manner. The court found his fraud-based argument was filed too late under the six-month rule. The court also rejected Lancaster's claim that the record was "forged" because the hearing master had said out loud during the hearing that he would pause (stay) the matter but then issued a written decision denying relief. The court explained that a judge's spoken statement in court is not binding, and a judge may enter a written order that differs from what was said aloud. Finally, the court declined to address Lancaster's argument about "prosecutorial misconduct," finding he did not explain it clearly enough for the court to consider it. The court also denied an emergency motion Lancaster filed to strike the record on appeal.

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.

Logan Fondren and Vanessa Lopez were married in January 2008 and have one child, born in January 2009. When they divorced in March 2010, the court adopted their settlement agreement: both parents shared legal custody, Vanessa had primary physical custody, and Logan paid $747 per month, representing child support and half of the child's health care costs. That figure was based on Logan earning $3,750 per month at the time. In January 2025, Vanessa - with help from the Washoe County District Attorney's Family Support Division - asked the court to review and update the child support amount, something Nevada law allows on a three-year cycle. The paperwork filed before the hearing showed that Logan's income had grown substantially: his own financial disclosure form listed gross monthly income of $9,550.06, along with his household expenses, his mortgage, and roughly $491 per month spent on three children (not from his marriage to Vanessa) who lived with him. After a remote evidentiary hearing, the district court found Logan's gross monthly income to be $11,032 and applied Nevada's child support formula, which calculates support as percentages of income in tiers. The formula produced $1,321 per month; the court then added $97 for the child's health insurance and subtracted $150 because Logan was responsible for supporting one other minor child, arriving at $1,268 per month. Logan appealed. The Court of Appeals rejected each of Logan's arguments. First, it found that the record contradicted his claim that the district court ignored his higher California cost of living and his obligations to his other children: his own financial disclosure form listed those costs, the district court said it considered all the evidence, and the court specifically gave him a $150 reduction for supporting another child. Second, to the extent Logan argued that he presented additional information at the hearing itself, he never filed a transcript of that hearing with the appellate court - even though the supreme court had sent him notices explaining that requirement. When an appellant fails to provide a necessary transcript, the appellate court must presume the missing transcript supports the lower court's decision. Third, on Logan's claim that the judge was biased or unfair, the court found no evidence that the judge relied on information from outside the case or displayed the kind of "deep-seated favoritism or antagonism that would make fair judgment impossible" that the law requires before relief is warranted. The court therefore affirmed the modified child support order.

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

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

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.

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

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

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.

Allison Schmidt and Erland Alan Fay married in 2019 and have one child. In 2022, Schmidt filed for divorce and asked for things like back child support, reimbursement for the child's health insurance premiums, and costs tied to her pregnancy. The case went to trial, but partway through, the two sides began settling their disputes by stating their agreement out loud "on the record" (meaning the terms were spoken in court and captured in the transcript). Schmidt said she was satisfied with most of the agreement on custody and child support, but at first did not want to give up two claims: reimbursement for her in vitro fertilization (IVF) expenses and past child support for periods when she cared for the child while the couple lived apart. The judge noted the parties were "stuck" and asked Schmidt to decide how she wanted to proceed. Fay then proposed a solution: he said Schmidt had loaned him $6,000 and he had repaid $4,500, and he offered to pay an additional $2,000. When the judge asked if $2,000 would "resolve it," Schmidt agreed. The judge described the $2,000 as a "settlement payment to resolve any other outstanding claims," and Schmidt responded, "[t]hat sounds good." When asked whether she fully agreed with the terms placed on the record, she said "Yes." The district court then wrote up a divorce decree based on that spoken agreement. The decree said Fay would pay Schmidt $2,000, which would serve as "full and final settlement of all past claims for child support arrears, labor/delivery charges, etc." Schmidt later changed course. She asked the court for relief from the decree, requesting a new trial on the financial issues and that the decree be corrected to match what she believed was actually agreed. Separately, several months after the decree, she received a Facebook friend request from the judge. On advice from the State Bar, she disclosed the friend request to Fay and tried to hire a lawyer for the upcoming hearing but could not find one on short notice. She asked the court to delay the hearing so she could obtain counsel. The court denied that emergency request and, after a hearing, also denied her motion for a new trial. On appeal, the Court of Appeals examined the trial transcript and concluded there was solid evidence that Schmidt had agreed the $2,000 payment resolved all of her remaining financial claims and that the decree accurately reflected that agreement. The court noted she never objected when the judge stated the payment would settle the outstanding claims, and she confirmed she was in full agreement. The court also rejected her argument about being denied a delay to hire a lawyer, finding she did not show she was harmed or that the result would have been different — particularly because the friend request happened months after the decree was already entered. To the extent she suggested the judge was biased, the court found she did not show the alleged bias came from outside the case or reflected the kind of deep hostility that would prevent a fair judgment. The court affirmed.

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

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

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

Hope Backman and Daniel Gelbman have a child together, born in 2013, and have been litigating child support for years. In 2019, Gelbman retired from firefighting at age 44 and started drawing a public retirement pension. He asked the court to lower his child support based on his reduced income. At a May 2020 hearing, the family court master concluded that Backman had not adequately documented her own earnings from her self-employed house-cleaning work, and the master "imputed" income to Backman equal to Gelbman's pension - meaning the master treated her as if she earned about $6,033 per month even though she may not have. Because the parents shared joint physical custody and were treated as having equal income, child support was set at zero. Backman filed several motions over the next few years to revisit child support, but each was denied and the zero-dollar order remained in place. In February 2023, she filed another motion, this time presenting documents showing she was earning roughly $600 to $800 per month from house cleaning, that the COVID-19 pandemic had affected her employment, and that she was behind on rent and car payments. A deputy district attorney at the hearing tried to explain to the master that Backman's documents showed a more than 20-percent drop in her income. Under Nevada law - specifically NRS 125B.145(4) - a 20-percent change in a parent's gross monthly income requires the court to review the child support order. The master cut the hearing short, said there had been no change in circumstances, and recommended leaving child support at zero. The district court agreed. The Court of Appeals reversed. The court answered two questions. First, when comparing income to determine whether there has been a 20-percent change, which prior order is the "controlling" one - the original order that actually calculated each parent's income, or any later orders that simply denied motions to modify without making new income findings? The court held that the controlling order is the most recent substantive order that set the support amount and made findings about each parent's income. Here, that was the May 2020 order, not the later denials. Second, what kind of evidence does a parent need to produce to trigger the mandatory review under NRS 125B.145(4)? The court held that the parent must present "prima facie evidence" - meaning credible evidence that, if accepted, would show the 20-percent change. Mere allegations are not enough, but a full trial-quality showing is not required at this threshold stage. Applying those rules, the court concluded that Backman's financial declaration, 2022 income information, profit-and-loss statement, supporting documents, and testimony that she was earning $600-$800 per month met the prima facie threshold and showed a more than 20-percent drop from the roughly $6,033 imputed to her in May 2020. The master was therefore required to conduct a substantive review - which would mean determining each parent's current income and applying the state's child support guidelines - and his refusal to do so was an abuse of discretion. The court sent the case back to the district court for that review. The court emphasized that requiring a review does not mean child support must actually be changed; it only means the court must look at the question on the merits. The Court of Appeals also explained what it was not deciding. It could not reconsider the May 2020 order itself, including the decision to impute income to Backman, because she did not appeal that order in time and did not list it in her notice of appeal.

Steven and Brianna Pierce divorced in 2013 and share joint legal and physical custody of their child, O.P. Under the original divorce decree, Steven kept the child on his health insurance and paid Brianna monthly child support, with a discount (called a "deviation") to account for the cost of insuring O.P. In 2022, Steven asked the district court to review child support. Brianna filed her own motion asking for a review as well. The district court recalculated child support and lowered Steven's monthly obligation. It also concluded that Steven had been claiming a larger health insurance deduction than the court had authorized, meaning Brianna had effectively overpaid her share of O.P.'s health insurance for years. The court ordered Steven to repay Brianna nearly $6,500. Finally, the court awarded Brianna attorney fees because she prevailed on two issues. Steven appealed. The Nevada Supreme Court reached several conclusions. First, it said it could not consider Steven's arguments about the QDRO order because Steven did not file a notice of appeal from that order within the 30-day deadline. Appellate courts only review what the appellant actually appealed. Second, the Court agreed with Steven that the district court made a mathematical error in calculating both parents' gross monthly incomes. The district court used a daily rate of pay to extrapolate annual and monthly income, but Steven actually receives 26 paychecks per year (paid every two weeks) and Brianna receives 24 (paid twice a month). The Court held that approach overstated both incomes and produced an erroneous child support figure, so it reversed that portion and told the district court to redo the calculation using the parties' actual pay schedules. Because of this, the Court did not need to address Steven's other arguments about Brianna's hiring bonus, certain adjustments under the child support regulations, or whether Steven should be reimbursed for support he overpaid while the motions were pending. Third, the Court rejected Steven's claim that ordering him to repay Brianna for past health insurance overpayments amounted to a "retroactive modification" of child support, which Nevada law forbids. The Court reasoned that the district court was enforcing the existing decree, which required the parents to share O.P.'s health insurance costs equally. The Court also rejected Steven's due process argument, noting that Brianna had asked for reimbursement in her own filings, so Steven had notice and a chance to respond. That portion of the district court's order was affirmed. Finally, because the underlying child support ruling was being sent back for recalculation, the Court vacated the attorney fees award so the district court can reconsider it after redoing the support calculation.

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

Hope Backman and Daniel Gelbman have a child born in 2013 and have been fighting over child support since shortly afterward. From 2014 to 2019, Gelbman paid Backman between $731 and $858 per month. In 2019, Gelbman retired from firefighting at age 44 and asked the court to reduce his payments because his income had dropped by more than 20 percent. At a May 2020 hearing, Backman gave the family court master a required financial declaration, Venmo records from her house-cleaning work, and bank account screenshots. The master decided those records were not enough to figure out her income, so he "imputed" income to her - meaning he assigned her an income figure - equal to Gelbman's, and set child support at zero dollars. Over the next few years, Backman filed several motions asking the court to change the zero-dollar support order, citing things like the COVID-19 pandemic wiping out her work and Gelbman allegedly earning money from real estate and substitute teaching. Some of those motions lacked supporting documents, and all were denied; support stayed at zero. In February 2023, Backman tried again, this time saying she was unemployed, close to homelessness, and wanted to relocate. Before the hearing she submitted a financial statement, her 2022 income information, a 2022 profit-and-loss statement for her cleaning business, a text from her landlord about being behind on rent, a past-due auto loan notice, and a list of jobs she had applied to. At the hearing, when Backman tried to explain that she had lost her cleaning job, the master interrupted and said it was his turn to talk. A deputy district attorney tried to point out that her documents showed a more than 20 percent income drop since the last hearing, but the master interrupted again, said there was no change of circumstances, and ended the hearing. He then recommended denying her motion. The district court affirmed. The Court of Appeals agreed with Backman that the master got it wrong. Nevada law (NRS 125B.145(4)) says a change of 20 percent or more in a parent's income counts as a "changed circumstance" that requires the court to review the support order. The court explained the difference between reviewing an order and actually changing it: presenting evidence of a 20 percent income drop does not automatically lower or raise support, but it does require the master to actually look at the order and run the numbers under the proper guidelines. Because the master refused to conduct that review and made only conclusory findings, the appeals court reversed and sent the case back for proceedings consistent with its order. One thing the court did NOT do was review the original May 2020 order that imputed income to Backman. Because Backman did not name that order in her notice of appeal, the court said it could not review that order for abuse of discretion. But the court still used the May 2020 order as the baseline (the "controlling order") for measuring whether her income had changed by 20 percent.

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.

Lindsay Marie Clark and Johnathan Matthew Harris share one minor child. After Harris filed for custody, the district court initially gave both parents joint legal and physical custody. Later, each parent asked to move out of state with the child - Harris to North Carolina, Clark to Colorado. After a hearing, the court decided it was in the child's best interest to live with Harris in North Carolina and gave him primary physical custody. At that time, the court calculated that Clark, whose gross monthly income was $2,166.67, would have owed $347 per month in child support, but Harris agreed to waive support because he earned more than Clark, so the court did not order Clark to pay anything. Clark later asked the court to set aside the order allowing Harris to relocate. Harris opposed that request and filed his own motion asking the court to modify the child support order, arguing that Clark's income had gone up substantially. Clark's updated financial disclosure showed her gross monthly income had increased to $4,290 - a jump of more than 20 percent from what she was earning when the earlier order was entered. Under Nevada law, an income change of 20 percent or more is treated as a changed circumstance requiring a review of the support order. The court found that modification was warranted and that Harris, as the parent with primary physical custody, was entitled to support. Using the standard formula, Clark's obligation would have been $686.40 per month. But the court reduced that figure for several reasons: $117 per month for Clark's expenses related to the child's travel between the parents' homes, $100 per month because Clark is financially responsible for another minor child, and a further adjustment because the child lives with Clark two months each year, during which she supports the child directly. The final result: Clark was ordered to pay Harris $469.40 per month for ten months of the year. On appeal, Clark made two main arguments. First, she said the court should not have ordered child support after Harris had waived it. The Court of Appeals rejected this, explaining that even when parents agree about child support, a district court "always has the power to modify an existing child support order, either upward or downward, notwithstanding the parties' agreement to the contrary," because child support involves public policy and the child's best interest. Since Clark's income had risen by more than 20 percent, the court was required to review the support arrangement, and its findings were supported by substantial evidence. Second, Clark argued the district court judge was biased against her. The Court of Appeals concluded relief was unwarranted because Clark did not show that the judge's decisions were based on knowledge acquired outside the proceedings, and the decisions did not reflect "a deep-seated favoritism or antagonism that would make fair judgment impossible." The Court of Appeals affirmed the district court's judgment.

Jeffrey Randall and Fanchon Brianna Caldwell have two children. One child is covered by a 2017 California child support order; the other is covered by a 2020 Nevada child support order. After the California order was registered in Nevada, Randall asked the Nevada family court to lower his support obligations and to set up a $1,000-per-month plan to pay down what he already owed (his "arrears"). He argued that the parties' financial situations had changed. In Washoe County family court, motions like this are first heard by a "master" - a court official who reviews the evidence and recommends a result to the judge. The master here did not believe Randall's claim that circumstances had changed, found him not credible on several points, kept in place the prior court's finding that Randall was willfully underemployed (so income could be "imputed" to him as if he were earning more), and recommended that Randall pay interest on the back-owed support. The district judge agreed with the master and denied Randall's objections. On appeal, Randall raised four main complaints. First, he argued that automatically sending child support cases to masters violates the constitution because it improperly hands judicial power to a non-judge. The Supreme Court declined to address the merits, holding that Randall was told his case would be heard by a master and that he could object, and because he did not object at the time, he gave up that argument. Second, Randall argued that the district court should have reviewed the master's findings from scratch ("de novo") rather than only checking for "clear error." He pointed to a 2019 amendment to NRCP 53. The Supreme Court rejected this argument because Randall did not raise it in the district court and did not provide a developed legal argument explaining why the rule change required de novo review. Third, Randall challenged the substance of the master's findings about changed circumstances, imputed income, and the addition of interest and penalties to his arrears. The Supreme Court found that "substantial evidence" - meaning enough credible evidence in the record - supported the master's conclusions, including the conclusion that Randall lacked credibility, that he was effectively trying to avoid paying child support entirely, and that he had not produced enough documentation to overturn the prior willful-underemployment finding. The court also rejected Randall's argument that NRS 125B.140 forbids charging interest on arrears, explaining that the statute actually permits it. Fourth, Randall complained that the master's order gave him only 30 days to submit proof of any overpayments he had made in California. The court noted that Randall did not show he had actually been harmed by the 30-day window - for example, he did not claim the District Attorney had refused to credit him for late-submitted proof - and stated it was confident he would be credited if he produces proof. The Supreme Court affirmed the district court's order in full.

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

Travis Anderson and Kerstin Morales divorced in December 2019. Under their joint divorce petition, the district court gave Morales primary physical custody of their three minor children and ordered Anderson to pay $1,400 per month in child support. In 2021, Anderson became unemployed and asked the court to lower his payments. At an April 2021 hearing, the parties agreed to reduce his obligation to $350 per child per month, and the court entered an order reflecting that agreement. During that hearing, Anderson emphasized that he was unemployed and that, absent an agreement otherwise, he would only owe $138 per month under a schedule used for low-income parents. In August 2022, Morales asked the court to raise the payments again, arguing that Anderson had found work and that his income had risen by more than 20 percent since the 2021 order. Nevada law treats a 20-percent-or-greater change in income as a reason to review a child support order. Anderson opposed the request, arguing mainly that his support could not be changed because of an income change. He said the 2021 agreement was tied to his moving to Oregon (which he did) and was meant to last until his duty to pay support ended. He also argued that, if the court did modify support, it should order a lower amount than the standard formula would produce. The district court modified Anderson's obligation to $1,320 per month for the two children who were still minors (his obligation for the third child had ended when she turned 18 and graduated high school). The court found that the 2021 agreement was not contingent on Anderson relocating and was not meant to apply forever, and that there was no basis to depart from the child support formula. Anderson asked the court to reconsider, raising for the first time claims that Morales's financial disclosure form contained mistakes and that the court had wrongly found his April 2021 monthly income to be $0. The court denied reconsideration, saying the transcript of the April 2021 hearing supported its decision and that any mistakes in Morales's form were inadvertent clerical errors. On appeal, the Court of Appeals affirmed. It explained that, as a matter of public policy, a district court always retains the power to modify child support, upward or downward, even when parents have agreed otherwise, so long as the legal criteria are met. Anderson had not argued that a legal doctrine called equitable estoppel should prevent modification, so the court treated that possibility as waived. The court also concluded that the record supported the finding that Anderson's income had risen by far more than 20 percent - from between $0 and $805 per month at the time of the 2021 agreement to roughly $6,000 when Morales moved to modify. Finally, the court held that the district court acted within its discretion in declining to lower the amount below the formula and in correctly applying the formula. Because Anderson relied on the same arguments to challenge the denial of reconsideration, that challenge failed too.

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.

Alfredo and Cristiane have two children together but never married. When their relationship ended, the children lived with Cristiane while Alfredo lived in Australia working as a circus performer. In December 2018, Cristiane filed a complaint asking for child custody, future child support, and arrears (past-due child support) dating back to 2007. Alfredo also filed his own custody complaint, in which he proposed paying $600 per month in child support. The district court combined the two cases. Because Alfredo was in Australia and did not answer, the court entered a default order in May 2014 giving Cristiane custody but leaving child support unresolved. After Alfredo moved to Las Vegas in 2016, the court granted him parenting time and set his child support at $600 per month in a June 27, 2016, order. Cristiane also filed a separate motion to review arrears going back to January 2014, but the court vacated that hearing. Alfredo then moved to reduce his support to $300, and at an August 18, 2016, hearing the court reduced his support and ordered him to pay $30 per month toward arrears. The written order from that hearing was not filed until June 2017 and left out language the court had stated at the hearing about how Cristiane should pursue arrears. In April 2022, Cristiane asked the court to hold Alfredo in contempt for failing to pay arrears and to modify his support based on his income. In August 2022, she asked the court to amend the August 2016 order to make clear she was entitled to arrears. Alfredo opposed, arguing the statute of limitations (a legal deadline for bringing a claim) had run out. After an October 2022 evidentiary hearing, the court amended the 2016 order "nunc pro tunc" - a Latin phrase meaning "now for then," used to correct a record to reflect what was actually decided earlier - to add the language that Cristiane could seek arrears. The court found the parties had a verbal agreement that Alfredo would pay $600 per month, that he was current until December 2013, and that he owed $47,160 in arrears plus $24,360 in interest. It also awarded $14,890 as a lump sum from Alfredo's "America's Got Talent" earnings and said attorney fees and costs were warranted. On appeal, the Court of Appeals agreed with the district court that Cristiane was entitled to arrears for December 2013 through July 2016. The court explained that the parties had a verbal agreement, that Alfredo had admitted in his own custody complaint that he would pay $600 per month, and that filing deadlines did not bar the claim because Cristiane's 2013 complaint tolled (paused) the statute of limitations. The court declined to consider Alfredo's laches argument because he raised it for the first time on appeal, and did not address the attorney fees issue because the fee order was not part of this appeal. However, the court agreed with both sides that the district court got the math wrong. Both parties agreed that a second amended schedule of arrears correctly listed $27,600 in arrears and $9,128.41 in interest, not the higher $47,160 and $24,360 figures in the order. It was also unclear from the record whether the $14,890 lump sum had already been paid. For those reasons, the court sent the case back for the district court to recalculate the amounts.

Shandell Stanisic and Thomas Shea have a child together, born in 2005. In 2006, while Stanisic was receiving public assistance from Nevada's Division of Welfare and Supportive Services (DWSS), the court found Thomas to be the father and ordered him to pay $100 a month in child support. Thomas was incarcerated at the time and did not try to change that amount. In 2009, Stanisic moved to Arizona. She says she told DWSS her new address but then heard nothing from the agency for eleven years and received no child support payments during that time. In 2021, after Thomas was released from incarceration, she contacted DWSS to enforce the old order, figure out how much back support was owed (called "arrears"), and update Thomas's payment amount because his income had changed. DWSS filed a notice setting a hearing before a "hearing master" (an official who hears certain family cases and recommends decisions to a judge). Oddly, although the notice referred to a "motion to modify," the record shows no such motion was actually filed. DWSS attached records, including an audit of Thomas's payment history. That audit showed that for the period from May 2009 (about when Stanisic moved) to August 2021 (when she got back in touch), Thomas's monthly amount owed was listed as $0 rather than the $100 set by the 2006 order. The hearing master concluded Thomas owed $5,809.97 in total arrears from 2006 to 2021 and set his new monthly support at $516. When Stanisic asked where Thomas's earlier payments had gone, the master told her to take that up with her caseworker. Stanisic objected, arguing the records were inaccurate because they left out roughly $14,700 in support that should have piled up between 2009 and 2021. DWSS responded, without citing any legal authority, that the case had become "recovery only," that arrears might not have accrued if a party was incarcerated, and that Stanisic had "waived" her claim through the "doctrine of Laches" (a legal principle about losing rights by waiting too long) because she lost contact with the agency. The district court affirmed the master without holding a hearing. The Court of Appeals reversed. It explained that under Nevada law, once a court orders child support, each payment becomes a judgment by operation of law when it comes due and cannot be reduced after the fact, and there is no time limit on collecting arrears. So unless someone had gotten the 2006 order changed, Thomas's $100 monthly obligation should have kept accruing the entire time, even if Stanisic's case with the agency had closed. The court also found the record too unclear to review: no proper motion was ever filed, and neither DWSS's paperwork, the master's report, nor the district court's order explained how the $5,809.97 figure was calculated, or even in whose favor the judgment was entered. Because it could not tell whether the arrears figure was money DWSS was recovering for public assistance it had paid, or support money owed to Stanisic, the court sent the case back for the district court to sort out the nature and amount of the arrears and Stanisic's entitlement to any further amounts. The court stressed it was taking no position on who is ultimately right about the arrears.

Albert and April Kagan divorced by a stipulated (agreed-upon) decree. They shared joint physical custody of their two children, and Albert was ordered to pay April $906 per month in child support. Later, Albert asked the court to lower his payments, saying more than three years had passed since support was last set and that his income had dropped by more than 20 percent. April did not argue against changing the amount in principle; instead, she disputed what the new figure should be and claimed Albert owed her back-owed support (called "arrears"). After a hearing, the district court lowered Albert's monthly support to $644.16. It also found that Albert owed $6,663.02 in arrears. Because Albert had been paying at the old, higher rate while his motion was pending, the court found he had overpaid by $1,407.36 and credited that against the arrears. That left $5,255.66 in arrears, which the court turned into a formal money judgment, ordering Albert to pay it off at $90 per month. The Court of Appeals reversed and sent the case back for two main reasons. First, on the amount of support, the court could not tell how the district court arrived at April's monthly income. Working backward from the figures used, the appeals court could see the district court had treated April's monthly gross income as $2,322 - but no matter which source of income information it looked at (April's paycheck stubs or statements her lawyer made at the hearing), the appeals court could find no formula that produced $2,322. Because the district court did not explain its math or state any reason for departing from the child support guidelines, the appeals court said it could not confirm the modified amount was supported by adequate evidence. Second, on the arrears, the appeals court found a due process problem. Albert had tried to argue that he had actually satisfied his support obligations, pointing in part to filings April made in a separate bankruptcy case that seemed to contradict her arrears claim. But at the hearing, the district court declined to consider Albert's arguments, simply adopted the $6,663.02 figure from an audit prepared by the Clark County District Attorney Family Support Division, and told Albert to raise any concerns with that agency directly. The appeals court held this denied Albert a meaningful chance to be heard before the court turned the arrears into a judgment - a deprivation of his property. The court sent both issues back to the district court for further findings and further proceedings. It also noted that because the overpayment credit depended on the modified support amount, the district court may need to recalculate the overpayment on remand.

Robert Haer and Carol Reyes were never married but share one child. In September 2020, Reyes filed a complaint asking a court to decide custody. Haer initially disputed that he was the father, and the court sealed the case to protect the child's privacy under a statute (NRS 126.211). DNA testing later confirmed Haer was the child's father. In May 2021, the court entered a temporary order. It adopted a parenting plan the parties agreed on and set temporary child support at $440 per month, based on Haer's reported monthly income of $2,749. Haer was also directed to pay an extra $100 per month toward $2,580 in back support (arrearages) dating from October 2020. The court made clear this support amount was temporary and would remain in place only until Haer's actual income could be verified. At trial, the parties agreed to admit several of Haer's financial records. Haer testified about his income, but the court found his testimony about how much he earned - and how much he was able to earn - was not believable. Looking at his bank records, tax documents, and other information, the court concluded that Haer was capable of earning much more than he claimed. The court decided he was "willfully underemployed" and treated him as if he earned $7,006 per month (this is called imputing income). Using that figure, the court set his monthly child support at $1,100. Because Haer's inaccurate financial disclosures had caused the earlier temporary support amount to be set too low, the court also had Reyes submit a schedule of what was actually owed. The court ultimately found Haer was $9,240 in arrears and ordered him to pay $100 per month toward that. The court also awarded Reyes $1,500 in attorney fees. Haer appealed. He raised three main points. First, he argued the court was wrong to impute extra income to him, saying it used outdated information, that his roofing business had declined, and that it ignored his poor health, criminal history, and inability to read or write. The appeals court disagreed. It explained that judges review these decisions for "abuse of discretion" and do not re-weigh a witness's credibility. The record showed the trial court actually did consider Haer's health, criminal record, and literacy, but concluded his own financial records showed he had earned substantial income and that his testimony conflicted with the documents. The appeals court also noted that Haer never provided a trial transcript, so it presumed the missing transcript supported the trial court's decision. Second, Haer argued the court had no power to change the support amount from what the temporary order set. The appeals court rejected this. As for the ongoing support in the final decree, no retroactive change was involved because those payments had not yet come due. As for the arrearages based on revised temporary payments, the temporary order itself said the amount was "without prejudice pending verification of [f]ather's income," so both sides were on notice the amount could change. Once trial revealed Haer's disclosure form was inaccurate, adjusting the amounts was permissible. Third, Haer challenged the attorney fees. Here the appeals court agreed with him in part. The trial court said it awarded fees under NRS 18.010 but did not specify which subsection, and did not make the required findings. It also failed to cite or apply a required consideration - the difference in income between the two parties. Because of this lack of clarity, the appeals court reversed the fee award and sent that issue back to the trial court to make proper findings. Everything else was affirmed.

Noune Davitian-Kostanian and Varoujan Kostanian divorced in 2012 after more than 25 years of marriage. Their stipulated divorce decree required Varoujan to pay Noune alimony for ten years (ending October 1, 2021) and to pay child support for their youngest son, Alex, who has autism, until he turned 18 (or graduated high school at 19). Alex turned 18 in 2015, and child support stopped at that time. One day before Varoujan's last alimony payment was due, Noune filed a motion asking the family court to (1) extend or modify alimony, and (2) restart child support for Alex as a disabled adult. The district court denied both requests. On child support, the court said it had no power to act because Alex was already an adult and support had ended years earlier. On alimony, the court found Noune had not shown a "change in circumstances." The Nevada Supreme Court partly agreed and partly disagreed. On child support, the Court held the district court was wrong to say it lacked jurisdiction. Nevada has a special statute, NRS 125B.110, that requires a parent to keep supporting a handicapped child past age 18 if the handicap arose before adulthood and the child cannot become self-supporting. Nothing in that statute requires the parent seeking support to ask before the child turns 18, and nothing imposes a deadline. The fact that more than five years had passed since Alex's child support ended is just one factor for the lower court to weigh, not a bar. The Court sent the case back so the district court can make findings about whether Alex qualifies for continued support. On alimony, however, the Supreme Court affirmed. NRS 125.150(8) says alimony "may" be modified on a showing of changed circumstances, and a 20-percent change in the paying spouse's gross monthly income triggers a review - but does not force the court to actually change the alimony. The district court considered Noune's arguments and reasonably concluded she had not adequately supported her claim of changed circumstances. That decision was within the trial court's discretion.

Justin and Lynsey Freelove were married for a little over a year and share one child. After the divorce, Lynsey was given primary physical custody of the child and lives in Nevada, while Justin lives in Idaho and shares joint legal custody. Before moving, Justin filed a motion apparently seeking primary physical custody and permission to relocate with the child. After hearings, his child support obligation was set at $750 per month in November 2019, and he was ordered to pay support starting in October 2019, when Lynsey was apparently awarded primary physical custody. Justin says he did not receive notice of the 2019 order, which is why he did not initially pay. The record does not show whether the order was actually served on him. Later, the district court entered an amended order clarifying that his obligation began in October 2019. Justin acknowledged he knew about this amended order and began making payments after receiving it, but he contested the past-due amount, arguing he had not been notified of the original 2019 order. By June 2020, he owed $6,031.59 in arrears, interest, and penalties. In February 2021, Justin got a new job in Idaho that cut his gross monthly income by about 33 percent. He asked the court to lower his child support to match his new, lower income. At the hearing before the court master, neither Justin nor Lynsey had a lawyer. The master decided there were no significant changed circumstances that would justify changing the support amount. Neither party filed a formal objection, so the master's decision became the court's judgment, and Justin appealed. The Court of Appeals ruled in Justin's favor on one point and against him on another. First, it rejected Lynsey's argument that Justin gave up (waived) his right to appeal by not objecting to the master's decision below. The court explained that failing to object only prevents you from challenging the master's report in the district court; it does not stop you from appealing to a higher court. Second, on the merits, the court agreed with Justin that the master made a mistake. Because Justin's income dropped by more than 20 percent, Nevada law required the master to conduct a review of the child support order. The master's one-sentence conclusion that there was "not a significant change of circumstances" did not include the specific factual findings the law requires. Importantly, the court noted that the master was required to review the order but was not required to actually change it. Because the master left the support at $750 when the guideline calculation would have produced $555, that had the effect of an "upward deviation" from the required amount without the necessary findings. So the court reversed and sent the case back for a new hearing. Third, the court rejected Justin's due process arguments about the interest and penalties on his arrears. It found he waived these arguments because he did not raise them before the court master and did not file a motion to set aside the earlier order. The court also noted he was present at the 2019 hearing with his lawyer, and that he failed to appeal the amended order clarifying the October 2019 start date.

This case is a dispute between two parents, James Ramseier and Nohelia Moldestad, who were never married but have one child together, named N.R. in the opinion. The child is about eleven years old. The parents had been sharing custody under a 2016 court order that set a parenting-time schedule and required them to agree in writing about the child's extracurricular activities. During the COVID-19 pandemic, the parents made a separate written agreement in 2020 for the 2020-2021 school year. That agreement covered how the child would be schooled (homeschooling for fifth grade) and a parenting-time schedule the parents described as each having the child "50% of the time." This 2020 agreement was never filed with the court. When disagreements arose, both parents went back to court. Moldestad asked to change the custody and holiday schedules, to use an app called Our Family Wizard to communicate, and for attorney fees. Ramseier asked the court to decide which middle school the child would attend, to change the schedule and holiday plan, and for attorney fees. They disagreed about which school was best, about the child's participation in synchronized swimming and how it affected Ramseier's time with the child, and about how child support should be calculated. The district court held a hearing and eventually ruled that the child would attend Sig Rogich Middle School (the school in Moldestad's zone), applying a set of ten factors the Nevada Supreme Court laid out in an earlier case, Arcella, for deciding a child's schooling. The court also ordered Ramseier to take the child to synchronized swimming during his parenting time and to share equally in the recurring costs of that activity, on top of his $2,000-per-month child support. On child support, the record showed that Ramseier had agreed (stipulated) to the $2,000 monthly amount. On appeal, Ramseier raised eight arguments, including that the judge was biased, that the court wrongly considered the child's progress at her current school, that the court did not fully analyze his alternative school choices, that tying school to Moldestad's residence was improper, that he should not be forced to take the child to an activity he did not agree to, that the court ignored the 2020 agreement's 50/50 schedule, that child support calculations should have accounted for both parents' household incomes, and that the upward deviation in child support for synchronized swimming was improper. The appeals court rejected each argument. On judicial bias, it found Ramseier had not overcome the presumption that judges are unbiased. On several points, it found he either failed to support his argument with legal authority, failed to object below, or took positions on appeal that contradicted what he had argued or conceded in the trial court (for example, he had stipulated to the child support amount and had testified he supported the swimming activity). On the school-choice order, the court noted that the order was not permanently fixed - it allowed for future modification if Moldestad moved or if the parents could not agree - so Ramseier had not shown he was harmed. On the 2020 agreement, the court found the parenting schedules were substantially the same as the 2016 order, that the 2020 agreement was only for a school year that had already ended, and that no substantial change in circumstances justified modification. The court affirmed the district court's judgment in full.

Bernadette Perez and Cornell Haywood were never married but have one child together, born in 2006. In 2011, Bernadette and the child moved to Texas, and Cornell has had limited contact with the child since. In 2017, Bernadette—with help from the Clark County District Attorney Family Support Division (DAFS), a government office that assists with child support—started a case seeking child support arrears (past-due support) for part of January 2017. The district court entered a consent order setting Cornell's monthly obligation at $462 and requiring him to pay $1,923 in arrears for January through April 2017. Bernadette did not sign that order and says she was never served with the filed copy. She later learned the order awarded only four months of arrears, rather than the maximum of four years that state law allows. In 2019, Bernadette hired a lawyer and asked the court either to modify the 2017 order or to enter a new judgment, seeking constructive arrears (past support the court can order for a period before the case was filed) going back four years. Cornell did not oppose her motion. DAFS, however, appeared and recommended denying it, saying Cornell had a right to rely on the earlier settled arrears. After objections and back-and-forth, the district court sent the matter to the hearing master for an evidentiary hearing on whether to award arrears for February 1, 2013 through December 31, 2016—the four-year window before Bernadette's 2017 support request. Before that hearing, the hearing master told Cornell to provide proof of his 2013–2016 income and told Bernadette to provide a schedule of arrears and medical expenses. Cornell did not object to Bernadette's proposed schedule and gave DAFS some tax documents but filed nothing before the hearing. At the hearing, both parties testified that Cornell provided no support for the child from 2013 to 2016. Cornell testified about his earnings: roughly $14,000 as an entertainer in 2013, about $10,855 in 2014, and around $16 an hour after starting a job in 2015 that continued into 2016. Cornell offered no argument against Bernadette's request. Neither side formally admitted the tax returns into evidence, and Bernadette submitted no additional documents. The hearing master declined to order more arrears, reasoning that Bernadette had failed to present evidence of Cornell's income or support for her medical-expense and insurance requests. Bernadette objected, and the district court affirmed. She then appealed. On appeal, the Court of Appeals reversed for several reasons. First, it declined to consider the brief filed by DAFS because DAFS did not represent any party to the appeal, and its arguments exceeded the authority the law gives it. Second, the court noted that Cornell never filed an answering brief despite being ordered to, and the court treated that failure as a confession of error. Third—and independently—the court concluded that the hearing master's report and the district court's order were not supported by substantial evidence, because the hearing master had actually received evidence (live testimony counts as evidence) about Cornell's failure to pay support and about his income, yet failed to fully consider awarding arrears or even the statutory minimum, or directing more discovery. The court sent the case back for a new hearing to determine whether four years of retroactive child support and payment of identified medical expenses is warranted.

Alfonso Estrada, an attorney living in Los Angeles, and Ida Arzola, who worked in Las Vegas, had a child together, A.E., born in May 2019. After the relationship ended, both parents went to court seeking primary physical custody - the arrangement where one parent has the child most of the time. Alfonso asked for primary custody; Ida asked for primary custody and also for child support (regular payments from one parent to help cover the child's needs). While the case was pending, the court set up a temporary schedule of joint physical custody, with the parents exchanging the child in Barstow, California, each week. During that temporary period, Alfonso was ordered to pay Ida $1,583 per month in support plus $5,000 in attorney fees, reflecting that Alfonso earns roughly ten times what Ida makes. After a two-day trial, the district court changed course. It awarded primary physical custody to Alfonso, ordered that the child's "habitual residence" stay in Nevada, and directed Ida to pay Alfonso $400 per month in child support. It also ruled that Alfonso, as the "prevailing party," could recover attorney fees, and later ordered Ida to pay Alfonso $40,000 in combined fees and costs. Ida appealed. The Court of Appeals split its decision into three parts. On custody, the court sided with Alfonso and left the custody award in place. It rejected Ida's argument that Alfonso had to meet a higher legal bar to "modify" custody, explaining that because no prior custody order existed, this was an initial determination, not a modification. It rejected her argument that the arrangement should have been called joint custody, noting that the best interest of the child is the main consideration and that percentage of time is only one factor. It rejected her argument that the court should have considered joint custody even though neither parent asked for it, in part because Ida herself never requested joint custody as an alternative. And it found the court's detailed analysis of the best-interest factors was supported by the evidence. On the relocation argument, the court declined to overturn the custody order. Ida had not raised the relocation issue in the lower court, cited no legal authority showing the relocation statute applied to her situation, and did not show that considering relocation factors would have changed the result. On child support, the court agreed with Ida. The district court had said "no adjustment evidence was provided" that would justify lowering Ida's payment - but its own findings described a large income gap (Alfonso earning about $250,000 a year while Ida attended community college), plus travel costs and Ida's limited ability to pay. Because that evidence supported considering a downward adjustment, the Court of Appeals reversed the support order and sent it back for the district court to apply the deviation factors. On attorney fees and costs, the court also agreed with Ida. The district court had awarded fees based only on Alfonso being the "prevailing party," without citing a legal basis, without making required findings, and without addressing the income disparity between the parties. The statutes Alfonso relied on did not fit the situation, and the order lumped fees and costs together without saying how much was which, making it impossible to review. The Court of Appeals reversed that award and sent it back as well.

This case is about a custody, child-support, and attorney-fee dispute between two parents of a young child. Alfonso Estrada is an attorney living in Los Angeles who met Ida Arzola in 2017 at a Las Vegas strip club where she worked as a dancer. They had a relationship, and a child, A.E., was born in May 2019. After the birth, the relationship became contentious. Alfonso asked the court for primary physical custody (meaning the child would live with him most of the time). Ida asked for primary physical custody too, and she also asked for child support. The parents agreed to share legal custody (decision-making about the child). While the case was pending, the court set up a temporary arrangement where they shared physical custody, exchanging the child each week in Barstow, California, and temporarily ordered Alfonso to pay Ida $1,583 per month in child support plus $5,000 in attorney fees. By this time, Ida was working as a food server earning about one-tenth of Alfonso's salary and had started nursing school. After a two-day trial, the district court awarded primary physical custody to Alfonso on a three-week-on, two-week-off schedule, with two extra weeks for Alfonso during the year. The court kept Nevada as the child's official home ("habitual residence") and set a status check before the child starts school. It also ordered Ida to pay Alfonso $400 per month in child support and awarded Alfonso attorney fees, saying only that he was the "prevailing party." Alfonso later asked for $48,217 in fees and $2,138.77 in costs; the court ultimately ordered Ida to pay a combined $40,000 in fees and costs, without saying how much was fees and how much was costs. Ida appealed. The Court of Appeals reached three main conclusions. First, on custody, the court upheld the district court's decision to give Alfonso primary physical custody. The court rejected Ida's arguments: that this was really a modification of an existing custody arrangement (it was not, because there had been no prior custody determination); that a case called *Bluestein* required treating the arrangement as joint custody (the court explained percentage of time is just one consideration and the child's best interest controls); that the court had to consider joint custody even though neither parent asked for it (Ida had not requested it and could not now complain of an error she helped cause); and that the court misapplied the best-interest factors (the court found the district court's detailed findings were supported by the evidence). Second, on the claim that the court improperly "relocated" the child to California, the court found Ida had not raised this argument below, had not cited supporting authority, and had not shown that a relocation analysis would have changed the outcome. Third, on child support and attorney fees, the court sided with Ida. On child support, the court held the district court should have considered whether to reduce Ida's payment given the large income gap between the parties, and it reversed and sent that issue back. On attorney fees, the court held the award could not stand because the district court gave no legal basis for it and failed to make required findings — including about the income disparity — and because Alfonso's own filings were deficient. The court reversed and remanded the fee-and-cost order.

This case is about whether Nevada's child support enforcement agency followed the required procedures before enforcing a California child support order against a Nevada resident. In 2013, a California court entered an order naming "Jonathan Jace Roosevelt Smith" as the father of a minor child and requiring him to pay $238 per month in child support. In 2017, the Nevada Division of Welfare and Supportive Services filed a document in Nevada that combined a "notice and finding of financial responsibility" with a notice registering the California order under the Uniform Interstate Family Support Act (UIFSA) - a law governing how one state enforces another state's support orders. Documents attached to the filing indicated Smith had not made payments and owed approximately $12,376 in arrears. Smith did not respond to the 2017 notice, but in 2021, after hiring a lawyer, he moved to void enforcement of the order. He alleged he was never served with notice of the California proceedings, the California order, or the 2017 Nevada notice, and that he only learned of the Nevada action when the agency intercepted $19,811.12 out of a $30,000 civil settlement paid to him by the Bureau of Prisons through the federal Treasury Offset Program. He also contended the California order was intended for a different person, as his name is "Jonathan Lee Smith," though the Court of Appeals noted he failed to present any evidence to support these assertions in the district court. The district court denied Smith's motion, reasoning that because the agency had previously notified Smith that his arrears were referred for federal collection, no additional notice was required before offsetting federal payments. But neither the district court nor the agency addressed Smith's argument that he was never served with the 2017 notice. On appeal, the agency admitted in its answering brief that it did not complete service of the Nevada notice on Smith in the manner required by statute, due to his incarceration. The Nevada Court of Appeals concluded the district court abused its discretion by failing to address Smith's non-service arguments. Nevada law requires that a notice and finding of financial responsibility be served on the parent, and that when an out-of-state support order is registered, the nonregistering party must be notified - requirements that protect a person's ability to contest the registration within a short window. Because Smith was never served, the district court effectively confirmed the amount of support and arrears he owed without giving him those protections. The court also concluded that the district court's finding that Smith received notice of the federal offset was not supported by evidence, because the only support for it was the oral argument of the agency's lawyer, and arguments of counsel are not evidence. The Court of Appeals vacated the district court's order and remanded, directing the district court to strike the 2017 notice. It clarified that this does not prevent continued enforcement of the California order by lawful means or a new registration proceeding, but any future attempt to judicially enforce the order in Nevada must comply with the registration and service requirements of NRS Chapter 130.

Carlos Guadron and Samantha Hayden share a daughter, Delilah, born in 2002. In 2006, a court ordered Guadron to pay child support to Hayden. Hayden and Delilah later moved to Minnesota, and Guadron says he had limited contact with Delilah until 2020. Over the years, the court adjusted the support order several times. In a December 4, 2013 order, the court set Guadron's monthly obligation at $110 (which included $10 toward past-due amounts) and converted about $14,475.28 in overdue support ("arrears") into a formal judgment. In 2020, Guadron went back to court. He asked to be paid back for support he had already paid, to cancel his arrears, or - if the court would not do those things - to waive the statutory interest that had built up on the arrears because he was facing financial hardship. He explained that he had recently reconnected with Delilah and learned she had not been living with her mother, that she was then 17 and living on her own with a child of her own. On the hardship point, he said he was unemployed because of the COVID-19 pandemic and was the primary physical custodian of his other minor daughter. He submitted financial documents showing $3,935 in monthly expenses against only $1,876 in monthly income from unemployment benefits. The district court found that because Delilah had turned 18, Guadron's ongoing support obligation had ended. The court did not calculate exactly how much he still owed, but directed him to keep paying $110 a month toward the arrears. It denied his motion with little explanation, saying only that the "[c]ourt found no hardship." On appeal, the Court of Appeals split its decision in two parts. First, it upheld the refusal to reimburse Guadron or erase his arrears. Under Nevada law, once child support payments come due they become a judgment automatically and cannot be undone or reduced after the fact. So Guadron could not get back money he already paid or wipe out arrears that had already accumulated. Second, on the request to waive the interest on the arrears, the court noted that Hayden never filed a response despite being ordered to do so and being warned of the consequences. The court chose to treat her silence as a "confession of error" - meaning it accepted, for purposes of this issue, that Guadron's argument had merit. It therefore reversed the part of the order refusing to waive interest and sent the case back to the district court. On remand, the district court must calculate the remaining arrears and interest that accrued after the December 4, 2013 judgment, and reconsider whether paying interest would create an undue hardship for Guadron. Importantly, the court noted the interest-waiver provision does not apply to amounts already reduced to judgment in the 2013 order - so only interest on arrears not covered by that judgment can be considered for waiver.

Nechole Garcia and Evgeny Shapiro were once a couple and had one child together, A.G.-S., who was later diagnosed with autism spectrum disorder. When their relationship ended, they could not agree on how to share custody or how much child support should be paid, so the case went to court. After a two-day trial, the district court decided the parenting schedule, set Garcia's child support obligation, and dealt with requests about past-owed support. Garcia appealed, raising several complaints about how the trial judge handled the case. The Court of Appeals rejected most of Garcia's arguments but agreed with one. First, Garcia argued the judge improperly let in evidence about settlement talks between the parties. The court disagreed. It explained that the materials she pointed to were never actually admitted as evidence. Arguments in motions are not evidence, and each time Shapiro tried to ask her about negotiation-related matters at trial, her objections were sustained (upheld) or the information was struck (removed) from the record. Because nothing was admitted, there was no error - and even if there had been, she never showed it harmed her case. Second, Garcia argued the judge failed to properly weigh the high level of conflict between the parents when choosing a parenting schedule. The court found that the judge had, in fact, considered the conflict, expressly noting it was high, and had weighed Garcia's point (that her schedule would mean fewer exchanges and possibly less conflict) against other factors. The judge picked Shapiro's proposed schedule as being in the child's best interest, and the court found enough evidence to support that decision - including that the parents had identical work schedules and that Shapiro's schedule would let A.G.-S. spend more time with her half-siblings, with whom she had a close bond. Third, Garcia argued the judge miscalculated Shapiro's income for child support by relying on his most recent tax return instead of bank deposits she said totaled more than $90,000 in 2020. The court found the judge did consider those bank deposits but concluded that deposits do not automatically equal income, especially since Garcia asked Shapiro about only one deposit (which he said came from pandemic-related unemployment assistance). Faced with conflicting evidence, the judge was entitled to rely on the tax returns, disclosure forms, and testimony, and the appeals court would not second-guess that. Finally, Garcia argued the judge wrongly refused to decide her request for child support arrears (past-due support) by mistakenly stating she had not asked for any. Here the court agreed with Garcia. The record showed she repeatedly requested "constructive" arrears - in her countermotion, her pretrial memorandum, an admitted exhibit, and her closing brief - claiming Shapiro owed $16,638.72. Because the judge declined to rule based on a mistaken belief that she never asked, the court reversed that portion and sent the matter back for the district court to actually decide the arrears request. Everything else was affirmed.

Bart and Bonnie Mahoney married in 2000 and had two children. When Bart filed for divorce in 2016, the couple reached an agreement that was merged into the divorce decree. Under the decree, Bonnie received primary physical custody of the children, and Bart agreed to pay child support, cover the children on his medical insurance, pay monthly alimony for five years, pay Bonnie 25% of his annual bonuses (rising to 35% if he failed to give her his annual W-2 tax forms), and pay her attorney fees and costs from the divorce. According to the opinion, Bart did not pay the child support, alimony, or attorney fees, did not pay Bonnie a share of his bonuses, and did not provide his W-2 forms. In May 2019, Bonnie asked the district court to reduce the arrearages (the unpaid amounts) to a judgment—that is, to convert what Bart owed into an enforceable court judgment—with interest and penalties, and to review child support and award her attorney fees. The case wound its way through several hearings. Bart's attorney withdrew in 2020 because Bart had never formally retained him and had stopped communicating. After that, Bart represented himself. The evidentiary hearing was rescheduled several times and ultimately set for December 3, 2020. Notice of that hearing was mailed to Bart's last-known address on file with the court, and Bonnie's attorney also emailed Bart pretrial filings—containing the hearing's date and time—at the same email address Bart had previously used to correspond with that attorney. Bart did not show up at the December 3, 2020, hearing. The district court proceeded with only Bonnie and her attorney present, took evidence including Bart's income and bonus records obtained by subpoena, and granted Bonnie's motion. It found Bart owed child support, alimony, and attorney fees and costs from the divorce, and—because Bart never provided his W-2 forms—awarded Bonnie 35% of his bonuses. It also awarded Bonnie the attorney fees and costs of bringing the motion, setting the amount in January 2021 after Bonnie filed a detailed memorandum of her fees and costs. Bart then moved to set aside the orders under NRCP 60(b), claiming he was never notified of the hearing, but filed his notice of appeal before the district court ruled on that motion. The appeal was still properly before the Court of Appeals under NRAP 4(a)(6), which treats the premature notice as filed on the date the district court denied the set-aside motion. However, because Bart's briefs did not address the denial of that motion, any challenge to it was waived. On appeal, the Court of Appeals rejected all three of Bart's arguments. First, it held that substantial evidence supported the finding that Bart was properly notified of the hearing: notice was mailed to his last-known address (which under the court rules completes service upon mailing), and he also had actual notice via emails from Bonnie's attorney. Bart pointed to nothing in the record—such as a sworn affidavit—showing he did not actually receive notice, and the onus was on him to keep the court updated with his address. Second, the court held that Bart's challenges to the arrearage findings were waived because he never raised those specific arguments in the district court, despite multiple opportunities to do so. Third, the court held that the fee award was not an abuse of discretion: the award was authorized by statute, and the district court made detailed findings under the four-factor test from Brunzell v. Golden Gate Nat'l Bank for evaluating the reasonableness of attorney fees.

Lillian Hargrove and Thomas Ward had a son together but were never married and never went to court to set up a formal child support order while their son was growing up. After the son turned 18, Hargrove sued Ward, asking the court to order Ward to pay her back child support for the years she had primary care of the child. She made two arguments: (1) Ward had promised in writing (through text messages and a course of conduct) to pay $400 per month, and Nevada law makes such written promises enforceable; and (2) even without an agreement, Nevada law lets a parent who had physical custody recover up to four years of past child support from the other parent. The trial judge said he did not have the power to award child support after the child had already become an adult, and so he denied Hargrove's request. Hargrove appealed. The Nevada Supreme Court split the issues. On the written-promise theory, the Court agreed with the trial judge that Ward never made the kind of clear, specific written promise that the statute requires. Text messages saying things like "Yes" to a single deposit request, or promises to send money "as soon as i can," were either too narrow or too vague to count as an enforceable promise to pay ongoing monthly support. So that part of the trial court's ruling was affirmed. On the retroactive child support theory, however, the Court reversed. It held for the first time that a parent can sue for retroactive (back) child support even after the child has reached the age of majority, as long as the lawsuit is filed within three years of the child's 18th birthday - the same window Nevada gives for filing a paternity action. The recovery is still capped at four years of support immediately before the lawsuit was filed. Because Hargrove filed her case roughly 15 months after her son turned 18, her request was timely, and the trial judge was wrong to say he lacked authority to consider it. The case was sent back to the district court for further proceedings.

Aaron and Tracy Romano divorced in 2019. They have seven minor children. Before the divorce decree was entered, they signed a stipulated order resolving custody. Under that arrangement, the three oldest children spend roughly 90 percent of their time with Aaron, and the four youngest spend roughly 95 percent of their time with Tracy. Even though those percentages would not normally count as "joint physical custody" under Nevada law (which generally requires each parent to have the children at least 40 percent of the time), the parties agreed to label the arrangement joint physical custody. They also signed a Marital Settlement Agreement (MSA) setting Aaron's child-support payments and Tracy's alimony, and providing that the prevailing party in any litigation over the MSA would get attorney fees. About eight months later, Aaron asked the court to officially relabel the arrangement: he wanted the order to say he had primary physical custody of the three older children and Tracy had primary physical custody of the four younger children. He also asked the court to recalculate child support, both because of the actual time-share and because, he said, Tracy's monthly income had jumped from $0 to about $6,018. Tracy responded that nothing had actually changed - the time-share was exactly what they had agreed to, and her income (alimony plus interest on a promissory note Aaron pays) was already known and built into the deal. The district court denied Aaron's motion. It said there was no change in circumstances justifying a custody change, suggested Aaron was really trying to manufacture a change so he could take advantage of new child-support guidelines, and found Tracy's income had not actually changed. It then awarded Tracy attorney fees and costs. On appeal, the Nevada Supreme Court used the case to clear up a recurring confusion in its own prior decisions. Earlier cases had suggested that courts use one test to modify "joint" physical custody and a different test to modify "primary" physical custody. The Supreme Court held that there is just one test, regardless of label: the parent asking to change the arrangement must show (1) a substantial change in circumstances affecting the children's welfare, and (2) that the change would serve the children's best interest. The Court overruled the part of its earlier Rivero decision that had implied a district court must first figure out which kind of custody actually exists before deciding whether to change it. Applying that single test, the Court agreed with the district court that nothing meaningful had changed in the short time since the parties signed their agreement. The actual time-share was the same one the parties had agreed to. On child support, the Court held that Nevada's new child-support guidelines (in NAC Chapter 425, effective February 2020) do not, by themselves, count as a "change in circumstances" that lets a parent reopen support. A specific regulation, NAC 425.170(3), says exactly that, and the Court ruled the regulation is a valid exercise of the agency's authority. Tracy's income also did not count as a change, because it was already factored into the original agreement. Because Aaron lost on the merits, Tracy was the prevailing party, and the attorney-fees award (based on the MSA's fee-shifting clause and NRS 18.010(2)(b)) was upheld.

Aaron and Tracy Romano divorced in 2019 and have seven minor children together. Before the divorce decree was entered, the couple signed a stipulated order spelling out a complicated custody timeshare: the three oldest children spend roughly 90 percent of their time with Aaron, and the four youngest spend about 95 percent of their time with Tracy. Even though those percentages would not normally qualify as "joint physical custody" under Nevada law (which generally requires each parent to have the child at least 40 percent of the time), the parents agreed to call it joint physical custody anyway. They also signed a Marital Settlement Agreement (MSA) that set Aaron's child-support payments and other financial terms. About eight months later, Aaron asked the district court to "confirm" that the actual living arrangement was really primary physical custody (not joint), and to recalculate child support accordingly. He argued two things had changed: the actual time-share with the children, and Tracy's monthly income, which he said had risen from $0 to about $6,018. He also argued that Nevada had adopted new child-support guidelines (NAC Chapter 425, effective February 1, 2020) and that the new guidelines were themselves a change of circumstances justifying a recalculation. The district court denied the motion, found Aaron had not shown any change in circumstances, awarded Tracy her attorney fees, and Aaron appealed. The Nevada Supreme Court affirmed. The Court used the case to clean up an inconsistency in Nevada custody law. For years, courts had applied two different tests depending on whether parents had "joint" or "primary" physical custody. The Court now holds there is just one test: to modify any physical custody arrangement, the parent asking for the change must show (1) a substantial change in circumstances affecting the welfare of the child, and (2) that the modification serves the child's best interest. The Court overruled portions of its earlier decision in Rivero v. Rivero to the extent that case suggested a district court must first figure out whether the existing arrangement is "really" joint or primary before ruling on a motion to modify. Applied to Aaron's case, the Court held the district court reasonably found nothing had substantially changed in the few months between the stipulated order and Aaron's motion. The custodial timeshare was the same one the parents had agreed to, and Tracy's income reflected payments (alimony and interest on a promissory note from Aaron) that were part of the same global settlement. On child support, the Court held that Tracy's income had not actually increased post-MSA - it was already what the parties used when they set support. As to the new state child-support guidelines, the Court pointed to NAC 425.170(3), a regulation stating that adoption of new guidelines, by itself, is not a change in circumstances sufficient to modify an existing child-support order. The Court held that regulation is a valid exercise of the agency's authority delegated by NRS 425.620 and NRS 425.450(1), and it carves out a narrow exception to the general rule that a change in the law can be a change in circumstances. Finally, because Tracy was the prevailing party and the MSA and NRS 18.010(2)(b) authorized fees, the Court upheld the attorney fees award.

Leslie and Brett Miller divorced in 2015. They have two minor children. Through mediation they agreed on most issues, including custody: they share joint physical custody of one child, but Leslie has primary physical custody of the other child, who lives with her and stays with Brett every other weekend. They could not agree on child support. The trial judge ordered Brett to pay Leslie $345 per month. When Leslie asked the judge to explain how he reached that number, the judge said he had "run the numbers" using statutory percentages (18% for one child and 25% for two children) along with deviation factors permitted by Nevada law, but did not show the calculations. Leslie appealed. The Nevada Supreme Court took the case to answer a question it had never directly answered before: how do you calculate child support when parents share joint physical custody of one child but one parent has primary physical custody of another child? Several different formulas had been proposed by the parties and by the State Bar of Nevada's Family Law Section, producing wildly different numbers from $345 to $832.19 per month. The Court walked through Nevada's child support statutes. NRS 125B.070 sets baseline percentages of a parent's gross monthly income that the parent owes for child support, based on the number of children (18% for one child, 25% for two, etc.). The Court emphasized that this percentage depends on how many children the parents have, not on the custody arrangement. After that obligation is calculated, the custody arrangement determines who pays what to whom. The Court announced this step-by-step formula for the Millers' "split custody" situation: 1. Calculate each parent's support obligation under NRS 125B.070 based on the total number of children (here, 25% of each parent's gross monthly income because there are two children). For Leslie, that was $996.67; for Brett, $1,076.24. 2. Divide each parent's obligation by the number of children to get a per-child amount. Leslie: $498.34 per child; Brett: $538.12 per child. 3. For the child in joint physical custody, offset the per-child amounts (under the Court's prior decision in Wright v. Osburn): the higher earner pays the lower earner the difference. Brett owed Leslie $39.78 for the joint-custody child. 4. For the child in Leslie's primary physical custody, Brett owes the full per-child amount ($538.12) with no offset. 5. Add those two figures together: Brett owes $577.90 per month. 6. Make sure the result does not exceed the presumptive maximum amount per child in NRS 125B.070(2). 7. The district court may then deviate from that amount under NRS 125B.080, but if it does, it must make written findings of fact explaining the deviation and stating what the support amount would have been under the formula. Because the trial court used the wrong starting percentage (18% for one child rather than 25% for two), failed to state the pre-deviation amount, and failed to explain the deviation factors that produced $345, the Supreme Court reversed and sent the case back with instructions to follow the formula above. The Court also flagged an "anomaly": under its formula, Brett owes $577.90 for two children, but if there were only one child in Leslie's primary physical custody, he would owe $774.80. The Court noted that this is a matter for the legislatively created Committee to Review Child Support Guidelines to consider, since the Legislature in 2017 (through A.B. 278) directed that new guidelines be developed.

Dawnette and Christopher Davidson divorced in 2006. Their divorce decree said that Dawnette would sign over her interest in the marital home to Christopher (using a "quitclaim deed," which is a document transferring whatever ownership rights one person has in property to another). In exchange, Christopher was supposed to pay Dawnette half of the equity in the home, based on a 2006 appraisal. About two weeks after the divorce, the two reconciled and lived together in the home until 2011, though they never remarried. Dawnette signed and delivered the quitclaim deed in 2006. Christopher says he later refinanced the home and paid Dawnette her share; Dawnette says he never paid her. In 2014 - eight years after she delivered the deed - Dawnette filed a motion in the family court asking the court to enforce the decree and order Christopher to pay her. Christopher argued that her claim was too old: Nevada has a six-year deadline (a "statute of limitations") for actions to enforce a court judgment, and that deadline had passed. The district court agreed with Christopher and denied her motion without deciding whether Christopher had actually paid. On appeal, Dawnette made two main arguments. First, she said that family courts have a special, unlimited power to enforce divorce decrees under NRS 125.240, so the six-year deadline should not apply. Second, she said even if the deadline did apply, the clock should not have started running until 2011, when the couple finally separated for good - because while she was still living in the house, it was not reasonable to expect her to demand payment. The Nevada Supreme Court rejected both arguments and affirmed the district court. The Court explained that NRS 125.240 applies to "separate maintenance" cases (a different kind of family law action), not to divorces. The Court also pointed out that when the Legislature has wanted to exempt certain family-law claims from a deadline, it has said so explicitly - for example, NRS 125B.050 says there is no time limit on collecting back child support. Because the Legislature has not done that for property-division provisions in divorce decrees, the ordinary six-year deadline in NRS 11.190(1)(a) applies. As to when the clock starts, the Court held that under NRS 11.200 and a long-standing 1892 Nevada decision, Borden v. Clow, the statute of limitations began running when Dawnette delivered the quitclaim deed in 2006. That was the moment Christopher's debt to her arose. Because she did not file her motion until 2014, more than six years later, her claim was too late. The Court also noted that Dawnette could have used NRS 17.214 to renew the judgment and avoid this problem, but did not. The Court acknowledged Dawnette's concern that this rule could give an ex-spouse a "windfall" by simply waiting out the deadline, but said the Legislature has also chosen not to let people "sit" indefinitely on potential claims.

After Larry Major was arrested in 2012 for child abuse, the State placed his daughter in the custody of Washoe County Social Services, which housed her at a facility called Kids Kottage for about seven months. Two different courts then got involved in the question of who pays for her care. First, a family court ordered Major to pay child support of $100 per month directly to Social Services. Later, after Major pleaded guilty to one felony count of child abuse, the criminal court (the district court) was asked to order restitution - a payment a convicted defendant makes to compensate a crime victim for costs caused by the crime. Social Services asked for $20,362.07, based on the rate it charges other agencies for care at Kids Kottage. Major objected. His main argument was that because the family court had already told him what to pay for his daughter's care, the criminal court had no authority - no "jurisdiction" - to order a much larger payment for the same thing. The district court disagreed and ordered restitution of $19,662.07, which was the amount Social Services sought minus a $700 credit for what Major owed under the family court's support order over the seven months. The Nevada Supreme Court affirmed. It explained that the two orders serve different purposes and come from different sources of authority. Family courts handle child support, which is calculated from a parent's income and is designed to keep a child out of poverty. But only a criminal sentencing court has the statutory power to award restitution to a crime victim - and the family court had no power to compensate the State for the costs Major's criminal acts imposed on it. Because the two obligations overlapped for the same seven months of care, however, the court noted with approval that the district court subtracted the $700 support obligation from the restitution figure. The Supreme Court held that the district court had jurisdiction to award restitution to the extent its order did not overlap with the existing family court support obligation. Major also argued that the restitution amount was not properly proven, in part because Social Services might have received federal reimbursement of up to 56 percent of the cost of care for eligible children. A Social Services fiscal compliance officer, Ida Peeks, testified about how the rate was calculated but did not know whether Major's daughter qualified for that reimbursement or whether any was received. The Supreme Court found the evidence sufficient, noting that Major made no showing that a reimbursement was actually received and that the district court required Social Services to notify it if a reimbursement came in, so the restitution order could be revised. The judgment of conviction was affirmed.

Hony Fernandez and Jennifer Fernandez (now known as Jennifer Rothman) divorced in 1998 after a brief marriage that produced two children. Both worked in the securities industry. The original divorce decree required the father to pay $3,000 per month in child support, plus health insurance, uncovered medical expenses, a housekeeper, and a nanny or day care. In 1999, the parties agreed to raise support to $4,000 per month (effective 2001) and to add private-school tuition. In 2000, after a failed reconciliation, they entered a third stipulation giving both parents joint physical custody — and in that stipulation, both parents "voluntarily waive[d] any right they may have pursuant to Chapter 125B of the Nevada Revised Statutes" to seek modification of the father's child support obligation. By 2007, according to the father's motion, his fortunes had reversed dramatically. He had once earned between $500,000 and more than $4,000,000 a year trading securities, but heavy market losses beginning in 2002 left him earning $3,000 a month selling cars, plus a similar amount in interest — while his child support obligations totaled roughly $80,000 a year. The mother, meanwhile, had remarried; her household income equaled or exceeded his, and the two had comparable net worth. The trial court itself found that if it applied the statutory child support formula to the parties' current incomes, "neither party would be obligated to pay child support to the other." Even so, it refused to modify the order, relying on the parties' waiver and on the fact that the father could still pay from his remaining assets. The Nevada Supreme Court reversed. It held that parents cannot, by agreement, strip a court of its statutory power to review and modify child support. Once a support agreement is incorporated into a divorce decree, it becomes a court order, not just a private contract, and Nevada's statutes provide for its periodic review and modification — up or down — as circumstances change. Quoting a California decision, the court concluded that "the court always has the power to modify a child support order, upward or downward, regardless of the parents' agreement to the contrary." The court also rejected the trial court's approach of requiring the father to draw down his assets before modification could be considered, and it rejected the mother's argument that her partial performance of the agreement barred the father from challenging it. One limit remained for the father, however. Under the court's recent decision in Rivero v. Rivero, the mere fact that more than three years had passed since the last review entitled him to a review, but not automatically to a modification: on remand, he must still demonstrate changed circumstances. The court noted that his alleged income drop — more than 80 percent — appears to satisfy the statutory trigger, under which a change of 20 percent or more in the support obligor's gross monthly income is deemed a changed circumstance requiring review for modification.

Michelle and Elvis Rivero divorced, and their divorce decree said they would share "joint physical custody" of their young child — but the actual schedule gave the child to Ms. Rivero five days a week and Mr. Rivero two days a week. Neither parent was ordered to pay child support. About a year later, Ms. Rivero went back to court asking for primary custody and child support, claiming Mr. Rivero rarely spent time with the child himself and lacked suitable living arrangements. The trial judge, Judge Miley, kept the joint-custody label in place, denied child support, sent the parents to mediation to work out a schedule, and eventually changed the schedule to an even 50/50 split, saying she was "just trying to find a middle ground." Along the way, Ms. Rivero asked Judge Miley to step off the case (a request called recusal), and when the judge refused, formally moved to disqualify her, claiming the judge was biased based on the parties' physical appearance. The chief judge rejected that motion as meritless, and Judge Miley then ordered Ms. Rivero to pay Mr. Rivero's attorney fees for having to fight a frivolous motion. On appeal, the Nevada Supreme Court used the case to answer a question Nevada law had never resolved: what exactly is "joint physical custody"? The court adopted Missouri's definition — an arrangement giving each parent "significant, but not necessarily equal" time with the child, structured so the child has "frequent, continuing and meaningful contact with both parents." In other words, joint custody does not require an exact 50/50 split, but each parent's time must be significant and meaningful. Applying that framework, the supreme court held the trial court went wrong in two ways. First, it labeled the arrangement joint physical custody without making specific factual findings to back that up. Second, it changed the custody schedule to an equal split without making specific findings that the change was in the child's best interest — the touchstone for all custody decisions. Both rulings were sent back for a do-over under the new definition. On child support, the court held that a parent may be entitled to support under Nevada's child-support statutes regardless of what the divorce decree says, and that a court departing from the statutory amounts must explain why in specific factual findings. Because the trial court did neither, that ruling was also reversed. The supreme court also announced a new math formula — a modified version of its earlier Wright v. Osburn approach — for calculating support when parents share joint custody but split time unequally, accounting for both differences in income and differences in time spent caring for the child. Finally, the court sided with the trial judges on the bias claims. A judge is presumed unbiased, and unhappiness with a judge's rulings is not a legally recognized ground for disqualification; the record contained no evidence of bias. The attorney-fee award stood as well: the court rejected Ms. Rivero's argument that a statute shielding parties from contempt punishment for seeking a change of judge also shields them from paying attorney fees for filing a frivolous disqualification motion.

Rod Mason, a U.S. Air Force servicemember, married Martine Cuisenaire while stationed in Belgium. After about eleven years, Mason obtained a divorce in North Carolina, where the couple was living. The North Carolina judgment granted Mason the divorce, gave Cuisenaire primary physical custody of their child, gave Mason summer visitation, and stated that "there are no pending claims for post-separation support, alimony, or equitable distribution." It said nothing about child support. Cuisenaire and the child moved to Belgium; Mason was later stationed at Nellis Air Force Base in Las Vegas. After Mason failed to return the child to Belgium at the end of summer 2000, Cuisenaire won a federal court order under the Hague Convention and its implementing legislation requiring the child's return. In February 2002, she asked the Nevada state district court for post-decree child support, alimony, division of assets, and attorney fees, including back child support running from the date of the North Carolina divorce. The Nevada district court awarded her current child support, more than $10,000 in child support arrears under a Nevada statute (NRS 125B.030), and a portion of Mason's military retirement benefits, while denying alimony and setting a further hearing on other assets. On appeal, the Nevada Supreme Court addressed three main questions. First, it held that the North Carolina divorce judgment was entitled to "full faith and credit" - the constitutional requirement that courts of one state respect final judgments of another state unless the judgment was obtained by fraud, without due process, or without jurisdiction. Cuisenaire raised various attacks on the North Carolina judgment on appeal, but because she had not raised those attacks in the district court, the Supreme Court declined to consider them. Second, the court held that the Nevada district court should not have used NRS 125B.030 to award back support. That statute lets a custodial parent recover up to four years of past support when the parents are "separated," but the court concluded the term does not cover parents who are already divorced and are seeking support for the period after the divorce became final. Third, the court held that back child support was nonetheless available - just under North Carolina law rather than the Nevada statute. Because no North Carolina case answered whether a divorce judgment silent on child support counts as a child support order, the court looked to a Nebraska Supreme Court decision, Willers ex rel. Powell v. Willers, and agreed that a divorce decree that says nothing about child support does not prevent a court from later ordering support retroactively to the date of the decree. The court sent the case back to the district court to recalculate the arrears using North Carolina child support guidelines. It declined to review the military retirement issue, which the parties agreed was moot after Mason's death, and directed the district court to hold an evidentiary hearing on survivor benefits, an issue the district court had not yet decided.

Robert and Amy Metz divorced and shared custody of their child, with arrangements changing over the years. Amy receives two kinds of federal benefits: Supplemental Security Income (SSI), a welfare-type payment for poor and disabled people, and Social Security Disability (SSD), an insurance benefit funded by past payroll contributions for disabled workers. When Robert sought child support from Amy, the district court concluded it could not order Amy to pay any child support at all because she received these federal benefits. The court also denied Robert's request to change custody. The Nevada Supreme Court took up the main question: can a Nevada court require a parent to pay child support out of SSI or SSD? The answer differs for the two programs. For SSI, the court held that federal law (42 U.S.C. section 407) exempts these benefits from being used to pay debts, and this exemption preempts (overrides) Nevada's child support law. SSI is meant to give a poor person a minimum income to live on and is not based on past employment, so a court cannot count SSI as income or order child support to come from it. For SSD, the result is opposite. Because SSD is funded by the worker's own past payroll contributions - it is 'remuneration for employment' - Congress consented to letting these benefits be reached for child support. So SSD can be counted as part of a parent's 'gross monthly income' and used to calculate child support. The court therefore ruled that the district court was wrong to refuse to consider Amy's SSD benefits, and it sent the child support issue back for the court to properly determine Amy's obligation. On custody, the court affirmed the denial of Robert's motion because the record showed no significant change in circumstances since the prior custody arrangement.

Janice and Donald Edgington divorced in 1995 and had one son, Matthew. Donald agreed to pay child support at the statutory maximum until Matthew turned nineteen or graduated from high school. As that deadline approached, Janice asked the court to extend Donald's support obligation past majority, arguing Matthew was a 'handicapped' child who could not support himself. Matthew had a hearing impairment, attention deficit disorder, and bipolar disorder, and received special assistance in school. Janice also asked to increase the support amount and for attorney fees. Nevada's handicapped child support statute (NRS 125B.110) requires a parent to support a child beyond age eighteen if the child is 'handicapped,' which the statute defines as being unable to engage in 'any substantial gainful activity' because of a medically determinable impairment. The district court found Matthew was not handicapped under the statute, denied the extension, denied the request to increase support, and denied attorney fees. The Nevada Supreme Court clarified what 'handicapped' means. It held that a child is handicapped only if he cannot be financially self-supporting because of a qualifying physical or mental impairment. The key phrase 'substantial gainful activity' means work activity that results in the child being self-supporting - not just any activity like attending school. There must also be a connection: the impairment must be the reason the child cannot support himself. The court found the record did not focus on whether Matthew could support himself, so it reversed that part of the ruling and sent it back for the district court to apply the correct definition. The court affirmed the denial of an increase in the support amount, because Donald already paid the statutory maximum and there was no change in circumstances. But it reversed the denial of attorney fees, because the statute requires the court to either award reasonable fees in a support-enforcement matter or expressly find that paying them would cause undue hardship, and the district court had done neither.