## Facts

- Robert C. Murray died intestate in Nevada in August 2012.
- Joyce Slaughter claimed to be Murray’s daughter; a delayed Arkansas birth certificate issued in 1952 listed “Robert Murray” as her father.
- Murray and Joyce’s mother married in Arkansas, moved to Las Vegas, and raised Joyce; Murray never initiated proceedings to establish or dispute paternity during his life.
- Murray’s obituary identified Joyce as his only living child, and Joyce arranged and paid for his funeral.
- Murray’s sister and nephew petitioned ex parte for appointment as special administrators, treating Joyce as a stepdaughter and identifying themselves as intestate heirs.
- Joyce petitioned to revoke their appointment and sought appointment as administrator based on her status as Murray’s child; the sister and nephew sought to contest Joyce’s parentage and requested DNA testing.
- The probate commissioner recommended finding Joyce to be Murray’s child and giving her priority; the district court adopted the recommendation and appointed Joyce administrator.

## Issues

1. In a probate proceeding, must a dispute about whether a claimant is the decedent’s “child” be resolved under the Nevada Parentage Act (NRS ch. 126) rather than general probate statutes?
2. Do the decedent’s collateral relatives (sister and nephew) have standing as “interested parties” under NRS 126.071(1) to challenge the claimant’s parentage?
3. Is a parentage challenge barred by NRS 126.081(1) when brought more than three years after the claimant reached the age of majority?
4. If standing and limitations bar the challenge, is the claimant treated as the decedent’s child for intestacy and administrator-priority purposes?

## Decision

- The Nevada Supreme Court affirmed the order appointing Joyce as administrator.
- The Nevada Parentage Act governs parentage determinations even when the determination is sought for probate purposes.
- The sister and nephew were not “interested parties” under NRS 126.071(1) and therefore lacked standing to bring a parentage challenge.
- Any parentage challenge was also time-barred under NRS 126.081(1) because it was brought decades after Joyce reached the age of majority.
- Because the challenge was procedurally barred, Joyce remained the decedent’s child for intestate succession and had priority to serve as administrator.

## Legal Principles

- Parentage determinations for probate purposes are governed by the Nevada Parentage Act (NRS ch. 126), not by general probate provisions alone.
- Standing to initiate or contest parentage under the Act is limited to “interested parties” as defined by NRS 126.071(1); collateral relatives with only an economic stake in the estate do not qualify.
- Under NRS 126.081(1), a parentage challenge is barred if made more than three years after the child reaches the age of majority, including when the challenge is raised in a post-death probate context.
- When standing and limitations foreclose a parentage contest, probate administration proceeds on the claimant’s child status, including statutory priority for appointment as administrator in an intestate estate.

## Conclusion

The court held that parentage disputes affecting heirship in probate must comply with the Nevada Parentage Act; because the decedent’s sister and nephew lacked statutory standing and were time-barred, they could not contest the claimant’s child status, and the claimant had priority to administer the intestate estate.


In re Estate of Murray, 344 P.3d 419 (Nev. 2015)