Case library
Nevada family-law decisions, briefed for practice.
1201 decisions, organized by topic. Practitioner summaries with key holdings, posture, disposition, and the statutes cited - up front, where you need them. Every summary links to the full opinion.
Case Library = case briefs of the decisions themselves. For long-form explainers of the governing law, Guides; for the exact quotable passages, verified verbatim, the Canon.
101 cases · Child Support - NRS ch. 125B, ch. 425, NAC ch. 425.
ANASTASSATOS VS. ANASTASSATOS (CHILD SUPPORT)
Apr 3, 1996112 Nev. 317; 913 P.2d 652 · 27560 · Nevada Supreme Court
Affirmed in part and reversed in part: the judgment as to child support abatement, sharing of transportation costs, and the change to the support due date is reversed; the commencement date of the increased support is affirmed.The court affirmed in part and reversed in part a child support modification order. On the jurisdictional/due process issue, the court held that although Nevada is a notice-pleading jurisdiction, a party must be given…
JACKSON VS. JACKSON (CHILD SUPPORT)
Dec 19, 1995111 Nev. 1551, 907 P.2d 990 (1995) · 27153 · Nevada Supreme Court
Order vacated and remanded for either written findings of fact justifying a deviation from the statutory formula or a redetermination of the amount of child support.Per Curiam. The court vacated and remanded a child support modification, resolving a jurisdictional challenge, a findings requirement, and a question of first impression regarding a cohabitant's contributions.…
GARRETT VS. GARRETT (CHILD SUPPORT)
Jul 27, 1995111 Nev. 972, 899 P.2d 1112 (1995) · 24915 · Nevada Supreme Court
Affirmed. The family court's child support judgment was affirmed.By the Court, Springer, J. (Steffen, C.J., and Young, J., concurring). The court affirmed a child support award, construing the interplay of the NRS 125B.070 formula cap and the NRS 125B.080(6) deviation authority.…
KHALDY VS. KHALDY (CHILD SUPPORT)
Mar 30, 1995111 Nev. 374, 892 P.2d 584 (1995) · 25997 · Nevada Supreme Court
Reversed in part and remanded. The judgment as to the mother's child support obligation was reversed and the case remanded for a child support award conforming to the statutory guidelines.Per Curiam. The court reversed a child support award and remanded for an award conforming to the statutory guidelines, holding the district court improperly deviated on purely equitable grounds and effected an improper…
HEDLUND VS. HEDLUND (CHILD SUPPORT)
Mar 2, 1995111 Nev. 325, 890 P.2d 790 (1995) · 24808 · Nevada Supreme Court
Affirmed. The order dismissing the motion to modify child support was affirmed.Per Curiam. The court affirmed the dismissal of a district-attorney-initiated motion to modify child support, holding that NRS 125B.150 does not authorize a district attorney to represent a custodial parent in an action…
RODGERS VS. RODGERS (CHILD SUPPORT)
Dec 22, 1994110 Nev. 1370, 887 P.2d 269 (1994) · 23390 · Nevada Supreme Court
Reversed and remanded for entry of appropriate findings on the child support obligation.The court applied ordinary statutory construction - plain meaning unless it violates the act's spirit, no language rendered nugatory (McKay v. Bd. of Supervisors, 102 Nev. 644, 648, 730 P.2d 438, 441 (1986); Paramount…
WESTGATE VS. WESTGATE (CHILD SUPPORT)
Dec 22, 1994110 Nev. 1377, 887 P.2d 737 (1994) · 24370 · Nevada Supreme Court
Reversed and remanded with instructions.Child support is governed by NRS 125B.080, which requires application of the NRS 125B.070 guidelines to any post-July 1, 1987 support request (18% of income for one child, up to the statutory cap), with only limited…
MCKELLAR VS. MCKELLAR (CHILD SUPPORT)
Mar 30, 1994110 Nev. 200, 871 P.2d 296 (1994) · 23785 · Nevada Supreme Court
Affirmed in part (no waiver) and reversed in part (retroactive application of NRS 125B.050), and remanded to determine the amount of arrearages owed.Equitable defenses such as estoppel or waiver may be asserted by the obligor in a proceeding to reduce child support arrearages to judgment (Parkinson v. Parkinson, 106 Nev. 481, 483, 796 P.2d 229, 231 (1990)). Waiver…
SCOTT VS. SCOTT (CHILD SUPPORT)
Dec 6, 1991107 Nev. 837, 822 P.2d 654 (1991) · 21511 · Nevada Supreme Court
Remanded for determination of (1) the overtime to be included in the payor's gross income under NRS 125B.070; (2) the continued support for the handicapped child under NRS 125B.110; and (3) calculation of eighteen percent of the payor's gross income to support the handicapped child upon the younger child's majority.A child support award may be modified in accordance with the statutory formula regardless of a change of circumstances. Parkinson v. Parkinson, 106 Nev. 481, 483 n.1, 796 P.2d 229, 231 n.1 (1990) (citing NRS…
MINNEAR VS. MINNEAR (CHILD SUPPORT)
Jul 12, 1991107 Nev. 495, 814 P.2d 85 (1991) · 21273 · Nevada Supreme Court
Affirmed.NRS 125.210(3) gives the district court discretionary authority to change, modify, or revoke child support provisions in divorce decrees, reviewable only for abuse of discretion. Edwards v. Edwards, 82 Nev. 392, 393,…
NICHOLSON VS. NICHOLSON (CHILD SUPPORT)
Apr 30, 1991107 Nev. 279, 809 P.2d 1267 (1991) · 21192 · Nevada Supreme Court
Reversed.A URESA court may not modify or nullify a preexisting duty of support. Vix v. State of Wisconsin, 100 Nev. 495, 686 P.2d 226 (1984); see also Taylor v. Vilcheck, 103 Nev. 462, 470-71, 745 P.2d 702, 708 (1987) (URESA…
PARKINSON VS. PARKINSON (CHILD SUPPORT)
Aug 21, 1990106 Nev. 481, 796 P.2d 229 (1990) · 19629 · Nevada Supreme Court
Affirmed. (Per curiam.)The court affirmed the denial of a motion to reduce child support arrearages to judgment based on implied waiver. Entry of judgment for support arrearages under NRS 125.180 is a matter within the district court's…
RAMACCIOTTI VS. RAMACCIOTTI (CHILD SUPPORT)
Aug 21, 1990106 Nev. 529, 795 P.2d 988 (1990) · 20198 · Nevada Supreme Court
Reversed and remanded for further proceedings consistent with the opinion. (Per curiam.)The court reversed and remanded. The district court erred in concluding it lacked jurisdiction to extend the father's support obligation for the older child beyond her eighteenth birthday. Norris v. Norris, 93 Nev. 65,…
HOOVER VS. HOOVER (CHILD SUPPORT)
Jun 28, 1990106 Nev. 388, 793 P.2d 1329 (1990) · 20302 · Nevada Supreme Court
Affirmed. (Springer, J.; Young, C.J., Steffen, Mowbray, and Rose, JJ., concurring.)The court affirmed the district court's application of the child support formula. Under NRS 125B.070(2)(b), the statutory obligation for two children is 25 percent of the obligor's gross monthly income, and the district…
BARBAGALLO VS. BARBAGALLO (CHILD SUPPORT)
Sep 21, 1989105 Nev. 546, 779 P.2d 532 (1989) · 18757 · Nevada Supreme Court
Affirmed. (Springer, J.; Young, C.J., Steffen, and Mowbray, JJ., and Zenoff, Sr. J., concurring.)In a case of first impression under Nevada's 1987 formula child support statute, the court set out the framework for applying the formula in joint and shared physical custody cases and affirmed the award of the full…
FRYE VS. FRYE (CHILD SUPPORT)
Jun 25, 1987103 Nev. 301, 738 P.2d 505 (1987) · 17650 · Nevada Supreme Court
Affirmed.The court addressed whether the doctrine of equitable adoption may impose a duty to pay child support, holding that on these facts it may. Building on Sargeant v. Sargeant, 88 Nev. 223, 495 P.2d 618 (1972), the court…
MORELLI VS. MORELLI (CHILD SUPPORT)
Jun 26, 1986102 Nev. 326, 720 P.2d 704 (1986) · 16705 · Nevada Supreme Court
Reversed and remanded for determination of interest owing on the child support arrearages and entry of judgment.The court held that a child is an intended third-party beneficiary of a parents' support agreement (Lipshie v. Tracy Investment Co., 93 Nev. 370, 566 P.2d 819 (1977)) and, although children ordinarily lack standing…
BREEDLOVE VS. BREEDLOVE (CHILD SUPPORT)
Dec 6, 1984100 Nev. 606, 691 P.2d 426 (1984) · 15075 · Nevada Supreme Court
Reversed and remanded. ("Accordingly, the judgment is reversed, and the matter is remanded to the district court for further proceedings in accordance with this opinion.")By the Court, Manoukian, C.J. (Mowbray, Steffen, and Gunderson, JJ., concurring). After the respondent-father defaulted on Indiana child support, the appellant-mother obtained and recorded in Clark County an…
IN RE CUSTODY OF GULICK (CHILD SUPPORT)
Feb 24, 1984100 Nev. 125, 676 P.2d 801 (1984) · 14672 · Nevada Supreme Court
Reversed and remanded. ("Accordingly, the order of the district court is reversed, and this matter is remanded for further proceedings.")Per Curiam. Reviewing an order modifying custody and support under a Maryland divorce decree, the court identified three errors and reversed. First, ruling on the father's November 18 motion the following day, without…
KENNEDY VS. KENNEDY (CHILD SUPPORT)
Jun 25, 198298 Nev. 318, 646 P.2d 1226 (1982) · 13179 · Nevada Supreme Court
Affirmed in part; reversed and remanded in part, for calculation and inclusion of interest on the arrearages and for determination of a reasonable payment schedule. ("Affirmed in part; reversed and remanded in part.")In an action to domesticate a California divorce decree and recover child support arrearages, the district court granted full faith and credit, entered a $7,837 arrearages judgment, and prospectively reduced the…
BROWN VS. BROWN (CHILD SUPPORT)
Aug 21, 198096 Nev. 713, 615 P.2d 962 (1980) · 10739 · Nevada (SCOTN/COA)
Reversed and remanded for further proceedings consistent with the opinion.The Court (Manoukian, J.) reversed a summary judgment that had accorded full faith and credit to a foreign (Idaho) judgment for child support arrearages entered without notice to the obligor. Courts must give full faith…
DAWSON VS. DAWSON (CHILD SUPPORT)
Dec 11, 197995 Nev. 821, 603 P.2d 691 (1979) · 10421 · Nevada Supreme Court
Affirmed. ("Accordingly, the judgment is affirmed.")The court affirmed a post-decree reduction of child support from $150 to $100 per child per month. Modification of child support based on changed circumstances is committed to the sound discretion of the district court…
DYE VS. DYE (CHILD SUPPORT)
Nov 9, 197995 Nev. 761, 602 P.2d 182 (1979) · 10232 · Nevada Supreme Court
Reversed and remanded. ("We reverse and remand for trial upon the issues raised by the pleadings.")The court reversed the dismissal of an action to recover child support arrearages accrued under a 1964 divorce decree. The district court had erroneously concluded that its earlier refusal to reduce the arrearages to…
HILDAHL VS. HILDAHL (CHILD SUPPORT)
Oct 15, 197995 Nev. 657, 601 P.2d 58 (1979) · 10220 · Nevada Supreme Court
Affirmed. ("Affirmed.")The court affirmed a judgment for support arrearages and a contempt order against a father who unilaterally reduced fixed monthly support-and-maintenance payments when a child came to live with him. Accrued alimony and…
SCHWARTZ VS. SCHWARTZ (SUPPORT ARREARAGES)
Mar 15, 197995 Nev. 202, 591 P.2d 1137 (1979) · Nevada Supreme Court
Reversed and remanded for a new hearing.Per Curiam. Res judicata is an affirmative defense that must be specifically pleaded, NRCP 8(c), and failure to plead it is normally a waiver, Tolotti v. Eikelberger, 90 Nev. 466, 530 P.2d 106 (1974). An unpleaded…
MCINNIS VS. MCINNIS (CHILD SUPPORT)
Aug 9, 197894 Nev. 532, 582 P.2d 802 (1978) · 9911 · Nevada Supreme Court
Affirmed. ("the order denying Appellant's motion to modify the judgment and decree of divorce by increasing the child support payments must be affirmed. . . . we affirm.")The court affirmed the denial of a mother's motion to increase child support. Jurisdiction to modify rested on NRS 125.140(2) (Cavell v. Cavell), and review is for abuse of discretion (Edwards v. Edwards). Applying the…
LAIRD VS. LAIRD (CHILD SUPPORT)
Dec 30, 197793 Nev. 687, 572 P.2d 543 (1977) · 9127 · Nevada Supreme Court
Affirmed.This brief per curiam opinion affirms a district court's refusal, in a decree-modification proceeding, to order the mother to contribute to child support after custody of the parties' two minor children was awarded to…
NORRIS VS. NORRIS (CHILD SUPPORT)
Feb 16, 197793 Nev. 65, 560 P.2d 149 (1977) · 8967 · Nevada Supreme Court
Affirmed.The court (Thompson, J.) affirmed the termination of a father's decree-based child support obligation upon his son reaching the reduced age of majority. The 1972 decree ordered support 'until said children respectively…
PEOT VS. PEOT (CHILD SUPPORT)
Jun 24, 197692 Nev. 388, 551 P.2d 242 (1976) · 8231 · Nevada Supreme Court
Reversed and remanded. ("The order of the lower court is reversed. ... this case is remanded to permit consideration and resolution of the motion for arrearages, in light of this opinion.")The court construed the interaction between a divorce decree's child support provision and a later URESA reciprocal support order. URESA's purposes are to improve and extend the enforcement of support duties (NRS…
BINGHAM VS. BINGHAM (CHILD SUPPORT)
Aug 26, 197591 Nev. 539, 539 P.2d 118 (1975) · 8008 · Nevada Supreme Court
Reversed. ("Reversed.")The court construed a merged child support agreement against the backdrop of a mid-term statutory change in the age of majority. When the 1969 agreement and decree were entered, NRS 129.010 set 21 as the age of majority…
MYERS VS. MYERS (CHILD SUPPORT)
Jul 23, 197591 Nev. 488, 537 P.2d 1194 (1975) · 7888 · Nevada Supreme Court
Affirmed. ("Affirmed.")The court reviewed a modification reducing the father's child support obligation. The appellant mother contended the record did not show a change of circumstances warranting the reduction from $220 to $170 per month per…
JOHNSON VS. JOHNSON (CHILD SUPPORT)
Jul 17, 197490 Nev. 270, 524 P.2d 544 (1974) · 7325 · Nevada Supreme Court
Affirmed.The court affirmed a judgment enforcing a divorce decree's provision requiring the father to pay each child's college expenses. Where a party fails to object below to the form or content of documents offered in support…
MAULDIN VS. MAULDIN (CHILD SUPPORT)
Jun 7, 197288 Nev. 336, 497 P.2d 886 (1972) · 6685 · Nevada Supreme Court
Affirmed.The court affirmed an order setting aside as void an execution sale of the husband's real property, purchased by the wife under a writ of execution, on the ground that the underlying child-support arrearage judgment had…
REED VS. REED (CHILD SUPPORT)
Jun 7, 197288 Nev. 329, 497 P.2d 896 (1972) · 6668 · Nevada Supreme Court
Affirmed.The court reviewed a district court order entered on the wife's NRS 125.180 motion to reduce child support arrearages to judgment. The district court is vested with discretionary power to order entry of judgment for…
MEAKIN VS. MEAKIN (CHILD SUPPORT)
Jan 26, 197288 Nev. 25, 492 P.2d 1304 (1972) · 6609 · Nevada Supreme Court
Affirmed.The court affirmed the denial of a motion to reduce child support. The appellant's asserted changed circumstances - a health-related inability to practice dentistry, bankruptcy, and reduced income as a hospital orderly…
LEEMING VS. LEEMING (CHILD SUPPORT)
Nov 15, 197187 Nev. 530, 490 P.2d 342 (1971) · 6491 · Nevada Supreme Court
Affirmed; appellant ordered to pay respondent an additional $1,000 for counsel's services on appeal.The court affirmed the district court's refusal to apply NRCP 68 to post-judgment proceedings in a divorce matter. Following the divorce, the respondent moved under NRS 125.140(2) to increase child support and, on…
CHESLER VS. CHESLER (CHILD SUPPORT)
Jul 12, 197187 Nev. 335, 486 P.2d 1198 (1971) · 6447 · Nevada Supreme Court
Reversed insofar as it reduced the respondent's support obligations; affirmed in all other respects, with the proviso that no effect shall be given to provisions allowing the respondent to transport the children away from Las Vegas while he is not current on support obligations.The appellant challenged an order modifying a divorce decree that (1) reduced the respondent's child support from $25 per week to $17.50 per month per child; (2) ordered the respondent to pay $25 monthly toward child…
BAILEY VS. BAILEY (CHILD SUPPORT)
Jun 18, 197086 Nev. 483, 471 P.2d 220 (1970) · 6005 · Nevada Supreme Court
Affirmed.The sole issue was whether a divorce decree ordering the father to pay child support 'until further order of the court, or until they reached the age of their majority' states a claim, enforceable against his estate,…
NOBLE VS. NOBLE (CHILD SUPPORT)
Jun 10, 197086 Nev. 459, 470 P.2d 430 (1970) · 5972 · Nevada Supreme Court
Affirmed in all respects except as to the suspension of child support, which is remanded for adequate findings on the effect of suspension on the child's present comfort and future well-being.The appeal challenged a district court order that, as a sanction for the custodial mother's persistent denial of court-ordered visitation, suspended alimony and child support and relieved the father of maintaining the…
LAMB VS. LAMB (CHILD SUPPORT)
Nov 13, 196783 Nev. 425, 433 P.2d 265 (1967) · 5307 · Nevada Supreme Court
Affirmed. The court affirmed both the order adjudging the father in contempt and the order denying his motion to modify the decree.Batjer, J. The father appealed an order adjudging him in contempt and denying his motion to modify the divorce decree while he was in contempt. A 1963 property settlement agreement requiring $200 monthly child support…
MELAHN VS. MELAHN (CHILD SUPPORT)
Apr 2, 196278 Nev. 162, 370 P.2d 213 (1962) · 4439 · Nevada Supreme Court
Reversed. ("Reversed.")The court construed a court-approved settlement agreement that conditioned the father's obligation to reimburse medical and dental expenses on the mother's submission of verified bills from providers belonging to…
SCHMUTZER VS. SCHMUTZER (CHILD SUPPORT)
Mar 17, 196076 Nev. 123, 350 P.2d 142 (1960) · 4243 · Nevada Supreme Court
Reversed in part and affirmed in part. The court ordered stricken the portion of the modification order relieving the husband of the obligation to pay the $4,800 balance owing on the dwelling, and affirmed the order in all other respects (including the child-support reduction). No costs were allowed.By the Court, McNamee, C.J. On the wife's appeal from an order modifying a 1955 divorce decree, the court reversed in part and affirmed in part. Except as to child custody and support, the decree became final six months…
RIEMER VS. RIEMER (CHILD SUPPORT)
Jul 30, 195773 Nev. 197, 314 P.2d 381 (1957) · 3986 · Nevada Supreme Court
Affirmed. ("Affirmed. The appellant is awarded costs.")The mother appealed from an order reducing the father's child-support obligation, entered after he showed his income had been reduced by approximately one-half; the modification set support at $50 per month per child…
RIEMER VS. RIEMER (CHILD SUPPORT)
Oct 22, 195672 Nev. 257, 302 P.2d 483 (1956) · 3986 · Nevada Supreme Court
Motion for allowances denied. ("The motion for allowances is denied.")In this per curiam order on the wife's motion for allowances and a stay ad interim, the wife - having appealed from the order granting the husband's motion to modify (reduce) child support - sought a $25 clerk's fee,…
PAINE VS. PAINE (CHILD SUPPORT)
Sep 22, 195571 Nev. 262, 287 P.2d 716 (1955) · 3856 · Nevada Supreme Court
Reversed; order set aside and motion for modification directed to be denied. ("The order must be set aside and the motion for modification denied.")The father appealed from an order modifying the divorce decree to increase his contribution to the children's support. The 1952 decree approved a New York settlement agreement (which survived and was not merged into the…
GOODMAN VS. GOODMAN (CHILD SUPPORT)
Oct 10, 195168 Nev. 484, 236 P.2d 305 (1951) · 3669 · Nevada Supreme Court
Affirmed; each party to bear own costs. ("The order of the trial court is affirmed. Each party shall bear his own costs upon this appeal.")The mother appealed the denial of her motion to modify a divorce decree to increase child support from $25 to $100 per week. The 1948 decree, granting her custody of the parties' six-year-old son, had approved an…
STOCKS VS. STOCKS (CHILD SUPPORT)
Jul 24, 194764 Nev. 431, 183 P.2d 617 (1947) · 3493 · Nevada Supreme Court
Affirmed. ("Under authority of Williams v. Keller, supra, the order appealed from is hereby affirmed, with costs.")Appeal from an order changing the place of trial from White Pine County to Clark County (the defendant's residence) in a guardian's action for a child's support and reimbursement of expenses. Held: under N.C.L. secs.…
ENGLE VS. ENGLE (CHILD SUPPORT)
Dec 28, 194563 Nev. 98, 164 P.2d 750 (1945) · 3447 · Nevada Supreme Court
Reversed and remanded. ("... is reversed and the case is remanded to the lower court for proceedings consistent with this opinion.")Appeal from an order denying a motion to modify a 1944 divorce decree to add child support. The decree awarded custody to the mother and "expressly reserve[d] and retain[ed] jurisdiction over the said minor child" with…
LINDSAY VS. LINDSAY (CHILD SUPPORT)
Sep 5, 192952 Nev. 26, 280 P. 95 (1929) · 2783 · Nevada Supreme Court
Reversed; lower court directed to enter an order denying respondent's motion. ("The order appealed from is reversed, and the lower court is directed to enter an order denying respondent's motion.")Appeal by the plaintiff ex-wife from an April 18, 1927 order of the district court purporting to construe the support provisions of a March 22, 1924 divorce decree on the ex-husband's motion filed February 2, 1927.…
ATKINS VS. ATKINS (CHILD SUPPORT)
Sep 13, 192750 Nev. 333, 259 P. 288 (1927) · 2776 · Nevada Supreme Court
The judgment is affirmed.Appeal from the child-support provision of a divorce decree (no motion for new trial below). The defendant physician contended the court lacked jurisdiction to award $100 per month for the child where the complaint…
Every summary is independently verified against the source opinion; summaries are informational research aids, not legal advice, and no substitute for reading the decision. Topic groupings are derived automatically from each case’s category tag and cited statutes; a case may appear under two topics.
