Romano v. Romano
What is the standard to change custody after it has been established? In Romano, the Nevada Supreme Court held that “a court may modify a joint or primary physical custody arrangement only if (1) there has been a substantial change in circumstances affecting the welfare of the child and (2) the modification serves the best interest of the child.” Moreover, the Nevada Supreme Court further stated that “we overrule Rivero to the extent it indicates that a district court must first determine what type of physical custody arrangement exists before considering whether to modify that arrangement.”