1. Anderson-Alexander v. Moten, III, No. 90813-COA, Order Affirming in Part, Reversing in Part and Remanding (Unpublished Disposition, August 25, 2026)
Jasmine Anderson-Alexander and Wayne Moten III, never married, share one child born in July 2020. After Moten filed for custody in 2022, the District Court (Amy Mastin), noting extremely high conflict between the parties, entered a 2023 decree awarding Anderson-Alexander sole legal and physical custody, with Moten limited to supervised parenting time and a path to petition for unsupervised time upon meeting certain conditions. In December 2023, Moten moved to change parenting time, alleging that Anderson-Alexander was not complying with the decree and was withholding the child. After the court found that Moten had met most of the decree’s conditions and that Anderson-Alexander was not complying, and following further proceedings and a March 2025 evidentiary hearing, the District Court modified custody, awarding Moten sole legal and primary physical custody, and limiting Anderson-Alexander to two hours of supervised parenting time each Thursday.
Anderson-Alexander appealed, arguing that the District Court did not make sufficient findings to modify child custody. She contended that the court failed to properly consider whether a substantial change in circumstances had occurred, and improperly relied on pre-decree evidence. (Moten did not file an answering brief.) She did not specifically challenge the sole legal custody determination.
In Nevada, custody decisions are reviewed for abuse of discretion, and a court may modify physical custody only where the movant shows both a substantial change in circumstances affecting the child’s welfare, and that modification serves the child’s best interest; a custodial parent’s substantial interference with the other parent’s parenting time can constitute such a change. A court abuses its discretion when it labels an award “primary” physical custody where it is functionally sole physical custody. A sole physical custody award requires specific written findings beyond the best-interest factors, including that the noncustodial parent is unfit to live with the child, or that a primary custody arrangement allowing significant parenting time is not in the child’s best interest. The court must then order the least restrictive parenting time arrangement consistent with the child’s best interest, and explain why any greater restriction is warranted. Deference is not owed to legal error or to conclusory findings that may mask it, and arguments not raised on appeal are forfeited.
The Court of Appeals held that the District Court did not abuse its discretion in finding a substantial change in circumstances or in its best-interest analysis supporting a change of custody, given findings that Anderson-Alexander repeatedly violated court orders, interfered with Moten’s relationship with the child, and escalated the parties’ conflict, while Moten complied with the court’s orders. It affirmed the unchallenged sole legal custody award. However, the court held that limiting Anderson-Alexander to two supervised hours per week functionally awarded Moten sole physical custody, that the District Court abused its discretion by mislabeling as primary physical custody, and that the court failed to make the additional written findings Nevada law requires, including any finding of unfitness or explanation of why less restrictive alternatives were not feasible. The court Affirmed in Part, Reversed the physical custody and parenting time decisions, and Remanded for the District Court either to fashion a genuine primary custody arrangement giving Anderson-Alexander sufficient parenting time, or to make the findings necessary to support a sole physical custody award.
2. Ronchi v. Ronchi, No. 88799-COA, Order Affirming in Part, Reversing in Part, Vacating in Part and Remanding (Unpublished Disposition, August 31, 2026)
Robert and Joanna began dating in 2004. Joanna, a Polish citizen, left the U.S. in 2006 over her immigration status and returned in 2008. The day before their wedding, and while Joanna was 19 weeks pregnant, they signed a premarital agreement in Pennsylvania containing a Pennsylvania choice-of-law provision and designating certain assets as separate property. An attached financial disclosure listed Robert’s separate assets, including his equity interest in his business, Element 115, and retirement accounts. They later moved to Nevada, where Robert bought the marital residence in his sole name. After Joanna filed for divorce in 2022, the District Court (Bryce Duckworth) found the premarital agreement valid, awarded Joanna half of the portion of Robert’s Fidelity IRA attributable to his marital earnings, half the equity in the residence, confirmed Element 115 as Robert’s separate property, and awarded Joanna attorney fees.
Robert appealed and Joanna cross-appealed. Robert argued that the District Court wrongly gave Joanna a community-property interest in his separately titled Fidelity IRA and in the marital residence, contending that both were his separate property under the agreement. Both parties challenged the attorney fee award. Joanna argued that the premarital agreement was the product of duress and lacked full disclosure, so it should not have been enforced, and that she was entitled to a community interest in the increase in value of Element 115.
In Nevada, divorce decisions are reviewed for abuse of discretion, and choice-of-law principles allow parties acting in good faith to select the law governing their contract. Here, that meant that Pennsylvania law governed the substance of the agreement, while Nevada procedural law controlled. Contract interpretation is reviewed de novo, and a court construes an agreement as written without modifying its plain meaning. Under the governing substantive law, prenuptial agreements are presumed valid, the party attacking one must prove invalidity by clear and convincing evidence, and parties are bound absent fraud, misrepresentation, or duress. Separately, a confidential relationship such as marriage can support a claim of constructive fraud, which may justify imposing a constructive trust over property, regardless of how it is titled or the presence of a premarital agreement.
The Court of Appeals held that the District Court properly found the premarital agreement valid and enforceable, and correctly confirmed Element 115 as Robert’s separate property, Affirming those rulings. It Reversed the awards giving each spouse a share of the other’s separately titled Fidelity IRA, holding that the agreement’s plain language kept such property separate. It Vacated and Remanded the marital residence award, holding that the gift-presumption caselaw applied was the wrong framework, but that the facts implicate constructive fraud, so the District Court must determine on remand whether Joanna established constructive fraud giving rise to a constructive trust. The attorney fee award was Vacated in light of the partial reversal.
3. Buchanan v. Brewer, No. 91363-COA, Order of Affirmance (Unpublished Disposition, August 31, 2026)
Madison Buchanan and Corey Brewer, who never married, share one minor child, A.B., born in 2020. After their relationship ended in 2022, they informally shared joint legal and physical custody. When Madison’s husband took a job in Reno to be near his mother, who had been diagnosed with cancer, Madison accepted a Reno job of her own and moved up her relocation to late 2024. Corey responded by seeking joint legal and physical custody, and Madison moved for permission to relocate with A.B. The parties mediated a partial parenting agreement, and after a trial on physical custody and relocation, the District Court (Amy Mastin) denied Madison’s relocation request, awarded Corey primary physical custody, and found the best-interest analysis equal between the parents.
Madison appealed, challenging the award of primary physical custody to Corey and the denial of her request to relocate. She argued that she had shown relocation was in A.B.’s best interest and would confer an actual advantage, that the District Court wrongly found the best-interest factors in equipoise, and that the court improperly confined its analysis to the statutory best-interest factors instead of considering the totality of the circumstances.
In Nevada, custody and relocation decisions are reviewed for an abuse of discretion (meaning a decision unsupported by substantial evidence or clearly erroneous), and the reviewing court does not reweigh conflicting evidence. Where no prior permanent custody order exists, the relocation statute does not strictly govern, but may be used as a guide. The moving parent must first show a sensible, good-faith reason for the move, and then satisfy factors bearing on quality of life, honorable motives, and preservation of the other parent’s relationship with the child. In every case, the decision must rest on the child’s best interest, the relocating parent bears the burden of proving relocation serves that interest, and no single best-interest factor is given controlling weight.
The Court of Appeals held that the District Court did not abuse its discretion. Although the relocation statute did not strictly apply because there was no prior permanent custody order, the District Court properly used it as a guide, found that Madison had a good-faith reason to move, but permissibly concluded that the best-interest factors stood equal, so she failed to carry her burden of showing relocation was in A.B.’s best interest. Because those findings were supported by substantial evidence and the court would not reweigh the evidence, it Affirmed the judgment.
4. In the Matter of: E.C.; J.O.C.; M.E.C.; O.E.C. and V.R.C., Minor Children, No. 91256-COA, Order of Affirmance (Unpublished Disposition, September 3, 2026)
Miguel E.C. is the father of five minor children. In March 2025, the state filed a child-protection petition under NRS Chapter 432B alleging that Miguel caused the children mental injury of a non-accidental nature by making numerous allegations, later found false, that the children had been sexually abused by their mother and her relatives; that these false allegations subjected the children to medical examinations and investigations, and that Miguel coached the children to make false allegations, possibly driven by a mental health condition. The children were removed and placed with their mother. After an evidentiary hearing at which Miguel appeared, testified, and other witnesses testified, the District Court (Rhonda Kay Forsberg) found that Miguel committed abuse and neglect by mental injury, awarded the mother sole legal and physical custody, granted Miguel supervised parenting time, and closed the case.
Miguel appealed, challenging the abuse and neglect findings, contending that the state presented false evidence, that the children had in fact been sexually abused by their mother and relatives, and that he was not given enough time to present his allegations. He further argued that his due process rights were violated because he was rushed at the hearing, and that the District Court judge was biased against him.
In Nevada, a district court’s factual findings on a child-protection petition are reviewed for an abuse of discretion and upheld if supported by substantial evidence and not clearly erroneous, with credibility determinations reserved to the trial court. An appellant bears the burden of providing an adequate appellate record, and where a party fails to furnish the hearing transcript, the reviewing court presumes the missing transcript supports the district court’s decision. Constitutional claims are reviewed de novo, and due process requires only notice and a meaningful opportunity to be heard, while the scheduling of hearings rests within the trial court’s discretion. Claims of judicial bias generally must arise from an extrajudicial source, and adverse rulings alone are not disqualifying. A final order resolving such a petition is appealable.
The Court of Appeals held that it had jurisdiction because the order placing the children with their mother and closing the case finally resolved the petition, and was appealable. On the merits, it Affirmed. Because Miguel failed to provide the evidentiary hearing transcript, the court presumed that the record supported the District Court’s abuse-and-neglect findings, could not meaningfully review his evidentiary challenges, and would not disturb the trial court’s credibility determinations. His due process claim failed given the notice he received, his appearance and testimony, and the same lack-of-transcript presumption. He did not show disqualifying bias. The judgment was Affirmed.
5. Herrmann v. Herrmann, No. 92238-COA, Order of Affirmance (Unpublished Disposition, September 3, 2026)
Jeremy and Kelly Herrmann married in 2007 and share two minor children. Kelly filed for divorce in 2021. The April 2022 divorce decree awarded her sole legal and primary physical custody, and granted her request to relocate to California with the children. Kelly moved to California and later to Pennsylvania, where she began proceedings to modify custody. Because the parties and children no longer lived in Nevada, Kelly moved the Nevada court to relinquish jurisdiction, and Jeremy acknowledged he too was no longer in Nevada. In April 2024, after conferring with the Pennsylvania court, the District Court (Sandra Unsworth) relinquished jurisdiction. Jeremy appealed, and the Court of Appeals affirmed that decision in a prior appeal. In December 2025, Jeremy filed a new motion attacking the April 2024 court orders as void for failing to follow the statutory procedures for relinquishing jurisdiction and seeking reconsideration, which the District Court denied as already considered and rejected.
Jeremy appealed the denial, arguing that the April 2024 orders were void because the district court did not follow the procedures in Nevada’s uniform child-custody-jurisdiction statutes when relinquishing jurisdiction to Pennsylvania, and that the court erroneously declined to reevaluate its decision to relinquish jurisdiction.
In Nevada, the denial of a motion for reconsideration or to set aside a judgment is reviewed for an abuse of discretion, with factual findings given deference and legal conclusions reviewed de novo, and reconsideration is appropriate only on substantially different evidence or a clearly erroneous decision. A judgment is void only where the court lacked personal or subject-matter jurisdiction. Under the law-of-the-case doctrine, a legal decision made at one stage of a proceeding remains binding throughout the litigation and on any later appeal, and it cannot be circumvented by presenting a more detailed or precisely focused version of the same argument after further reflection.
The Court of Appeals held that Jeremy’s arguments were barred by the law-of-the-case doctrine because it had already affirmed the District Court’s April 2024 decision to relinquish jurisdiction to Pennsylvania in his earlier appeal, and a more detailed reformulation of that same challenge could not avoid the doctrine. Because Jeremy offered no compelling reason to revisit the prior decision and showed no applicable exception, the District Court did not abuse its discretion in denying his motion, and the judgment was AFFIRMED.
- New Cases Added to MLAW: 5 COA Unpublished: Anderson-Alexander, Ronchi, Buchanan, In the Matter of: E.C.; J.O.C.; M.E.C.; O.E.C. and V.R.C., and Herrmann - October 15, 2026
- New Cases Added to MLAW: 5 COA Unpublished: Carerra, Campbell, Plata, Ocasio, and Stevens - September 19, 2026
- Vol. 82 — The Evolution of Sole Custody in Nevada - September 15, 2026