Michael Robert Martin v. Danielle Palmer f/k/a Danielle Denise Martin

Las Vegas, Nevada family law divorce lawyers represented the parties in a marriage dissolution action.



Michael Martin and Danielle Palmer divorced in 2017. They then litigated multiple issues relating to their three children. Danielle eventually moved to appoint a parenting coordinator. The district court granted that motion and ordered the parties to submit an order appointing a parenting coordinator. Michael appealed, and we affirmed, noting that "Michael's arguments appear[ed] to challenge unknown actions the parenting coordinator may take in the future once one is appointed." Martin v. Martin, No. 85323, 2023 WL 3055103, at *2 (Nev. Apr. 21, 2023) (Order Affirming in Part and Dismissing Appeal in Part). The district court appointed a parenting coordinator after Michael refused to sign the proposed order or the parenting coordinator's contract. Michael filed a motion once again challenging the parenting coordinator before the parenting coordinator had taken any actions. The district court denied that motion and granted Danielle's countermotion for attorney fees and costs, awarding Danielle $2,000. Michael appeals. We review for an abuse of discretion, Miller v. Wilfong, 121 Nev. 619, 622, 119 P.3d 727, 729 (2005), and affirm.



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Legal issue Did the district court abuse its discretion in awarding attorney fees and costs in post-divorce proceedings, including fees for work performed by a law clerk?

Headnote



FAMILY LAW. ATTORNEY FEES AND COSTS. The case concerns an appeal from a district court order awarding attorney fees and costs in post-divorce proceedings, where the appellant challenged the appointment of a parenting coordinator and the propriety of the fee award without a hearing.



FAMILY LAW. DUE PROCESS. The appeal addressed whether the district court violated due process by failing to hold a hearing before awarding attorney fees and costs, with the court affirming the district court's actions due to the appellant having notice and a meaningful opportunity to be heard.



CIVIL PROCEDURE. ATTORNEY FEES FOR LAW CLERKS. The case examines whether the district court abused its discretion in awarding attorney fees for work performed by a law clerk, with the court ruling that such fees are permissible.



CIVIL PROCEDURE. REDACTED BILLING RECORDS. The issue involves whether the use of redacted billing records could support an award of attorney fees and costs, with the court affirming the sufficiency of the redacted entries.



APPELLATE PROCEDURE. SCOPE OF APPEAL. The appeal also addresses the limitation of the appellate review to issues designated in the notice of appeal, as well as the exclusion of constitutional challenges and other arguments outside the appeal's scope.



Key Phrases Attorney fees and costs. Parenting coordinator. Abuse of discretion. Redacted billing records. Constitutional challenges.

Affirmed