Nevada family-law decisions, briefed for practice.

This is an appeal from a district court order dismissing a custody petition for lack of standing. The Court of Appeals reviewed the dismissal de novo, applying "the same rigorous, de novo standard as dismissal for…

**Due process challenge.** The court restated that "[P]rocedural due process requires notice and an opportunity to be heard," Callie v. Bowling, 123 Nev. 181, 183, 160 P.3d 878, 879 (2007), and that "[d]ue process is…

Standard of review: subject matter jurisdiction is reviewed de novo; factual findings receive deference and are upheld if not clearly erroneous and supported by substantial evidence. Ogawa v. Ogawa, 125 Nev. 660,…

This is an original proceeding seeking extraordinary writ relief. The Court of Appeals set out the governing standards. A writ of mandamus is available to compel the performance of an act that the law requires as a duty…

The Court of Appeals reviewed four issues. **Subject matter jurisdiction (UCCJEA).** The court reviewed the district court's subject matter jurisdiction determination de novo, citing Ogawa v. Ogawa, 125 Nev. 660, 667,…

The Court of Appeals reviewed the district court's legal custody determination for abuse of discretion, citing Ellis v. Carucci, 123 Nev. 145, 149, 161 P.3d 239, 241 (2007), and Mack-Manley v. Manley, 122 Nev. 849, 858,…

Standard of review. The court reviews custody determinations for abuse of discretion, which occurs when the decision is unsupported by substantial evidence or is clearly erroneous. Ellis v. Carucci, 123 Nev. 145, 149,…

The Court of Appeals reviewed the custody determination for an abuse of discretion. Ellis v. Carucci, 123 Nev. 145, 149, 161 P.3d 239, 241 (2007). Deference to the district court's discretionary determinations is not…

The Court of Appeals reviewed several distinct rulings under differing standards. **Subject matter jurisdiction / registration of the foreign order.** The court reviewed subject matter jurisdiction de novo, giving…

The Court of Appeals reviewed the denial of a motion to set aside a divorce decree for abuse of discretion, citing Rodriguez v. Fiesta Palms, LLC, 134 Nev. 654, 656, 28 P.3d 255, 257 (2018), and Cook v. Cook, 112 Nev.…

The Court of Appeals reviewed the contempt order for abuse of discretion. Lewis v. Lewis, 132 Nev. 453, 456, 373 P.3d 878, 880 (2016); see also Vaile v. Vaile, 133 Nev. 213, 217, 396 P.3d 791, 794-95 (2017) (contempt…

The Court of Appeals reviewed subject matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA) de novo, citing Kragen v. Eighth Jud. Dist. Ct., 140 Nev., Adv. Op. 49, ___ P.3d ___…

The Court of Appeals reviewed each of Stephanie's four arguments under the abuse-of-discretion standard applicable to child custody determinations. Under that standard, the court focuses on whether the district court…

The Court of Appeals reviewed the district court's dismissal for lack of subject matter jurisdiction de novo, citing Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 704 (2009). It applied the deferential standard to…

Standard of review. Subject matter jurisdiction, including home state jurisdiction under the UCCJEA, is reviewed de novo. Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 704 (2009). De novo review "properly includes…

The appeal presented a question of subject matter jurisdiction over a guardianship petition. The court reviewed the issue de novo, citing Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 704 (2009) ("Subject matter…

**Service of process (waiver).** The court applied the rule that an objection to personal jurisdiction, process, or service of process is waived if not raised as a defense in an answer or pre-answer motion under NRCP…

The court reviewed subject matter jurisdiction de novo, citing Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 702 (2009), and reviewed the district court's underlying factual findings for clear error, deferring where…

The Court of Appeals reviewed the district court's denial of a motion to modify child custody without an evidentiary hearing for abuse of discretion, citing Myers v. Haskins, 138 Nev., Adv. Op. 51, 513 P.3d 527, 531…

The Court of Appeals reviewed the custody decision for an abuse of discretion, declining to disturb findings supported by substantial evidence, citing Rivero v. Rivero, 125 Nev. 410, 428, 216 P.3d 213, 226 (2009),…

The Court of Appeals granted mandamus relief directed at Eighth Judicial District Court orders assuming UCCJEA jurisdiction and establishing temporary custody in a divorce action. On jurisdiction, the court reiterated…

The Court of Appeals reviewed the question of subject matter jurisdiction de novo, citing Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 704 (2009). Subject matter jurisdiction over child custody is governed by NRS…

The court analyzed subject-matter jurisdiction under the UCCJEA, which both Nevada and Texas have adopted. The dispositive question was whether Nevada had authority to enter a child custody determination - which under…

The Court of Appeals resolved two unconsolidated appeals in a single order of affirmance. In Docket No. 85148-COA, Ward challenged the district court's "Order After Reversal and Remand" denying NRCP 60(b) relief. The…

The Court of Appeals reviewed the child custody determination for an abuse of discretion and reaffirmed that findings will not be disturbed if supported by substantial evidence - "evidence that a reasonable person may…

Standard of review: child-custody determinations, including parenting-time schedules, are reviewed for an abuse of discretion, Rivero v. Rivero, 125 Nev. 410, 428, 216 P.3d 213, 226 (2009), overruled on other grounds by…

This is an appeal from a family court order dismissing a child custody action under NRS 125A.365 on inconvenient-forum grounds in favor of California. The Court of Appeals addressed four assignments of error. On the…

**NRCP 60(a).** The court reviewed the denial of clerical-correction relief for abuse of discretion. Mack v. Estate of Mack, 125 Nev. 80, 93, 206 P.3d 98, 107 (2009); Frontier Ins. Serv., Inc. v. State, 109 Nev. 231,…

Standard of review: The court reviews a child support order for an abuse of discretion, Wallace v. Wallace, 112 Nev. 1015, 1019, 922 P.2d 541, 543 (1996); see also Flynn v. Flynn, 120 Nev. 436, 440, 92 P.3d 1224, 1227…

This is a matter of first impression interpreting NRS 125A.465, Nevada's UCCJEA registration provision. The court applied de facto plain-meaning statutory construction, citing Washoe Med. Ctr. v. Second Judicial Dist.…

The court reviewed the custody order for abuse of discretion under Wallace v. Wallace, 112 Nev. 1015, 1019, 922 P.2d 541, 543 (1996), and reviewed factual findings for substantial evidence under Ellis v. Carucci, 123…

**Standard of review.** The court reviewed the child custody order for abuse of discretion, leaving factual findings undisturbed if supported by substantial evidence. Wallace v. Wallace, 112 Nev. 1015, 1019, 922 P.2d…

The Court reviewed the constitutional due process question de novo, citing Callie v. Bowling, 123 Nev. 181, 183, 160 P.3d 878, 879 (2007), and reviewed application of the first-to-file rule for abuse of discretion,…

The Nevada Supreme Court resolved two questions on review: (1) the controlling child support order under UIFSA when a Nevada decree and a later Norway administrative order coexist, and (2) appellate jurisdiction over…

The Nevada Supreme Court reviewed UCCJEA jurisdictional questions de novo where the underlying facts are undisputed, citing Friedman v. Eighth Judicial Dist. Court, 127 Nev. 842, 847, 264 P.3d 1161, 1165 (2011). The…

Standard of review. Subject matter jurisdiction is reviewed de novo. Ogawa v. Ogawa, 125 Nev. 660, 667, 221 P.3d 699, 704 (2009). Factual findings are reviewed for abuse of discretion and upheld if supported by…

The court resolved two issues of first impression: (1) whether a Costa Rican spousal and child support order is enforceable in Nevada under UIFSA, codified at NRS Chapter 130, and (2) whether it may be enforced under…

**Standard of review and writ standards.** Unless the jurisdictional facts are disputed — and they were not here — subject matter jurisdiction under the UCCJEA presents questions of law reviewed de novo. Ogawa v. Ogawa,…

Standard of review. Subject matter jurisdiction is a question of law reviewed de novo. See Gosserand v. Gosserand, 230 S.W.3d 628, 631 (Mo. Ct. App. 2007); Harshberger v. Harshberger, 724 N.W.2d 148, 154 (N.D. 2006);…