Nevada Trust Writs: Adequate Statutory Remedies Bar Prohibition Relief; Document-by-Document Showing Required to Unseal/End Pseudonyms

1. Introduction

Case: IN RE: DOE IRREVOCABLE TRUST (CIVIL), No. 89107 (Nev. Jan. 8, 2026).
Posture: Original petition for a writ of prohibition filed by petitioner Sabina Singh against the Eighth Judicial District Court (Clark County) and the probate judge, with Premier Trust, Inc. and John Doe as real parties in interest.

The petition challenged the district court’s decision to exercise in rem jurisdiction over a Nevada trust. Singh asserted that the in rem trust proceeding prejudiced her claimed rights in trust assets that she contended were community property subject to division in a concurrent divorce proceeding in Washington.

Alongside jurisdictional objections, Singh also sought relief in the Supreme Court to (i) prohibit the parties’ use of fictitious names and (ii) unseal portions of the record that had been sealed in the district court.

2. Summary of the Opinion

The Nevada Supreme Court denied the writ petition, holding that extraordinary writ relief was unwarranted because Singh had a plain, speedy, and adequate remedy at law through the trust-proceeding remedial mechanism in NRS 164.033 and related statutory appeal rights. The court also denied Singh’s motions addressing pseudonym use and unsealing, concluding she failed to provide the focused, document-specific showing the court requested, while leaving her free to raise those issues in the district court. The previously imposed stay was lifted.

Separate writing: Justice Cadish, joined by Justice Lee, concurred in the denial of the unsealing/pseudonym motions but dissented from denying writ review, reasoning that Singh’s challenge included personal jurisdiction, for which appeal is typically inadequate and writ review is appropriate—especially given recent Nevada trust-jurisdiction case law.

3. Analysis

A. Precedents Cited

Club Vista Fin. Serus., LLC u. Eighth Jud. Dist. Ct., 128 Nev. 224, 228, 276 P.3d 246, 249 (2012)
Cited for the core definition and function of a writ of prohibition: an extraordinary remedy available when a district court acts in excess of its jurisdiction. The majority uses it to frame the high threshold for intervention.
Pan u. Eighth Jud. Dist. Ct., 120 Nev. 222, 224, 88 P.3d 840, 841 (2004) (and later citation to 120 Nev. at 228, 88 P.3d at 844)
Used for two points: (i) the general rule that the right to appeal is an adequate remedy that precludes writ relief and (ii) the petitioner’s burden in writ proceedings. The majority relies on Pan to emphasize that extraordinary relief is discretionary and not a substitute for ordinary litigation paths.
Smith u. Eighth Jud. Dist. Ct., 107 Nev. 674, 677, 818 P.2d 849, 851 (1991)
Supports the proposition that the decision to grant writ relief rests entirely within the Supreme Court’s discretion, reinforcing the court’s reluctance to intervene where statutory remedies exist.
Edwards v. Emperor's Garden Rest., 122 Nev. 317, 330 n.38, 130 P.3d 1280, 1288 n.38 (2006)
Invoked to deny the unsealing/pseudonym requests: the moving party must cogently argue and support claims with relevant authority. The court analogizes Singh’s failure to identify and justify unsealing “each individual document” to the sort of underdeveloped argument rejected in Edwards.
Viega GmbH u. Eighth Jud. Dist. Ct., 130 Nev. 368, 374, 328 P.3d 1152, 1156 (2014) (Cadish, J., dissenting in part)
Cited for the proposition that writ relief is an appropriate mechanism to challenge an allegedly invalid exercise of personal jurisdiction, because a “speedy and adequate” remedy generally does not exist otherwise.
Fulbright & Jaworski LLP u. Eighth Jud. Dist. Ct., 131 Nev. 30, 35, 342 P.3d 997, 1001 (2015) (Cadish, J., dissenting in part)
Reinforces that “the right to appeal is inadequate” to correct an invalid exercise of personal jurisdiction—supporting the dissent’s view that the petition warranted merits review.
In re Richard H. Goldstein Irreuocable Tr., 141 Nev., Adv. Op. 41, 575 P.3d 72, 77 (2025) (Cadish, J., dissenting in part)
A key, recent trust-jurisdiction decision: even with statutory in rem jurisdiction under NRS 164.010, due process may still require personal jurisdiction over a necessary party (there, the trustee). The dissent argues the district court’s approach—declining to evaluate personal jurisdiction because it had in rem jurisdiction—contravenes Goldstein.
In re Paul D. Burgauer Revocable Living Tr., 138 Nev. 801, 805-06, 521 P.3d 1160, 1165 (2022) (Cadish, J., dissenting in part)
Cited to emphasize that both NRS 164.010 and constitutional Due Process Clause requirements must be satisfied to assert specific personal jurisdiction over a nonresident trustee. The dissent uses it to show that “in rem” labeling does not end the jurisdictional analysis.
Archon Corp. v. Eighth Jud. Dist. Ct., 133 Nev. 816, 819-20, 407 P.3d 702, 706 (2017) (Cadish, J., dissenting in part)
Supplies an additional basis for writ review: the presence of “clear and indisputable” legal error. The dissent contends the district court’s refusal to analyze personal jurisdiction in light of Goldstein/Burgauer may qualify.

B. Legal Reasoning

1) Majority: Writ relief is inappropriate because statutory trust remedies and appeals are adequate

The majority’s reasoning follows Nevada’s standard writ framework: prohibition is extraordinary, and it is unavailable if the petitioner has a “plain, speedy, and adequate remedy at law.” The court identifies a structured statutory path within Nevada trust practice:

NRS 164.033(1)(a): permits “interested parties” to petition the probate court for an appropriate remedial order if they claim an interest in trust assets.
NRS 164.033(5): authorizes the probate court to grant appropriate relief on such a petition.
NRS 164.033(6), NRS 164.005(1), and NRS 155.190(1)(n): collectively establish that trust proceedings are subject to probate appeal provisions and that appeals are authorized from qualifying trust orders (including, as noted, when the amount in controversy is $10,000 or more).

In other words, the majority treats the dispute—whether and how Singh’s asserted property interest should be protected in the trust proceeding—as something the probate court can address first through remedial orders, with a statutory appeal to follow if needed. That availability of relief defeats the core prerequisite for writ intervention.

2) Majority: Motions on pseudonyms and unsealing denied for failure to make a document-specific showing

The court recounts a prior order (Oct. 9, 2024) denying Singh’s earlier requests to depart from the district court’s rulings and SRCR 7 (Supreme Court Rules governing sealed records), while inviting Singh to file a single, focused motion explaining why each individual document should be unsealed.

Because Singh did not provide a document-by-document analysis, the court denies the motions, citing Edwards v. Emperor's Garden Rest. for the principle that inadequately developed arguments will not be considered. The denial is “without prejudice” to raising the issues in the district court.

3) Dissent (Cadish, J.): personal-jurisdiction challenges justify writ review; in rem jurisdiction does not bypass due process

The dissent’s core point is procedural: Singh’s petition was not solely about in rem jurisdiction; it also contested personal jurisdiction over her. Under Viega GmbH u. Eighth Jud. Dist. Ct. and Fulbright & Jaworski LLP u. Eighth Jud. Dist. Ct., writ relief is particularly apt for personal-jurisdiction objections because an appeal is typically inadequate to remedy being haled into an unauthorized forum.

Substantively, the dissent relies on the court’s recent trust-jurisdiction decisions—In re Richard H. Goldstein Irreuocable Tr. and In re Paul D. Burgauer Revocable Living Tr.—to argue that a statutory in rem grant (referencing NRS 164.010) cannot “obviate” constitutional due process requirements. The dissent would therefore reach the merits to assess whether Nevada courts could properly exercise personal jurisdiction over Singh and whether she is a necessary party.

C. Impact

Channeling disputes into NRS 164.033 proceedings: The decision reinforces that, in many trust disputes, Nevada’s statutory remedial framework—followed by appeal—will be deemed adequate, limiting writ review even when a party alleges significant prejudice from the probate court’s assumption of control over trust assets.
Practical guidance for sealing/pseudonym challenges: The court signals that appellate requests to unseal or to end fictitious-name usage must be supported with a granular record: parties should identify each sealed document and provide a tailored justification (and supporting authority) for unsealing it, rather than presenting generalized objections.
Continuing tension in trust jurisdiction doctrine: The dissent underscores an unresolved boundary: when a trust court relies on in rem jurisdiction, due process may still require a personal-jurisdiction analysis for certain parties. Future litigants can be expected to invoke Goldstein and Burgauer to argue that in rem trust proceedings cannot proceed in ways that effectively adjudicate rights of nonresidents without constitutional contacts analysis.
Interstate conflict scenarios (trust vs. divorce/property claims): The case highlights recurring friction where a Nevada trust proceeding overlaps with an out-of-state marital dissolution. While the order does not resolve the merits of community-property characterization, it indicates the Nevada Supreme Court will generally require parties to litigate protective remedies within the Nevada trust forum first (and appeal if necessary), rather than obtaining immediate extraordinary intervention.

4. Complex Concepts Simplified

Writ of prohibition: An extraordinary order from a higher court telling a lower court to stop acting because it is exceeding its jurisdiction. It is not a routine shortcut; it is usually unavailable if ordinary procedures (motions, hearings, appeals) can address the problem.
In rem jurisdiction: Court power over a thing (here, trust property or the trust estate) located in the forum. It often supports probate/trust administration in the state where the trust is administered or property is located.
Personal jurisdiction: Court power over a person. Due process generally requires minimum contacts with the forum state before a court can bind a person with its orders.
“Adequate remedy at law” (why it matters for writs): If statutes provide a workable route to obtain relief—especially with a right of appeal—Nevada appellate courts will usually refuse extraordinary writ intervention.
Interested party petition (NRS 164.033): A statutory mechanism allowing someone who claims an interest in trust assets to ask the probate court for remedial orders (and then appeal qualifying orders).
Sealed records / SRCR 7: Nevada Supreme Court rules governing sealed materials. The order emphasizes that unsealing requests must be specific and justified document-by-document, not presented as broad objections.

5. Conclusion

The court’s order cements a pragmatic procedural rule in Nevada trust litigation: where NRS 164.033 provides a mechanism to seek remedial orders regarding claimed interests in trust assets—and where statutory appeals are available— the Supreme Court will generally deny writs of prohibition as unnecessary extraordinary intervention. At the same time, the order provides concrete appellate-practice guidance: challenges to pseudonym use and sealing must be tightly argued and document-specific.

The partial dissent signals an important doctrinal pressure point for future cases: even in trust proceedings framed as in rem under NRS 164.010, parties may press for writ review when personal jurisdiction is disputed, relying on Viega GmbH u. Eighth Jud. Dist. Ct., Fulbright & Jaworski LLP u. Eighth Jud. Dist. Ct., and the court’s recent trust due-process decisions such as In re Richard H. Goldstein Irreuocable Tr. and In re Paul D. Burgauer Revocable Living Tr..