Haley v. DIST. CT., 273 P.3d 855

In 2005, Ashley, a ward of the state with brain damage from birth, had a wrongful death/personal injury claim pursued by Gellner and guarded by Haley.
In 2010, the parties reached a $238,000 settlement; proposed allocations: Gellner $109,187.26, Haley $20,100, Medicaid $79,333.33, and Ashley $29,379.41, with Gellner submitting the petition for court approval.
The district court refused to approve the compromise as proposed due to attorney fees exceeding the minor’s recovery and directed a reallocation.
Gellner sought to have the district court approve the settlement again, while Haley submitted a hours statement for his guardian ad litem duties.
The district court eventually approved the overall $238,000 but reallocations to Medicaid and to “attorneys” without distinguishing between attorney fees and guardian ad litem fees.
Gellner and Haley filed a petition for writ relief (mandamus/prohibition) seeking clarification and challenge to the unilateral redistribution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether NRS 41.200 allows district court to redistribute a minor's settlement proceeds unilaterally	Gellner argues no statutory authority to modify proposed distribution.	District court may adjust the allocation to protect the minor's best interests under NRS 41.200.	Yes; district court may redistribute proceeds in the minor's best interests.
Whether the district court properly reviewed reasonableness of fees and allowed redistribution	Gellner contends the modification was unreasonable and not properly justified.	Court exercised broad discretion using Brunzell factors to determine reasonableness.	District court acted within broad discretion to modify the fee allocation.
Whether guardian ad litem fees were improperly combined with attorney fees	The district court failed to separate Gellner's attorney fees from Haley's guardian ad litem fees.	Not addressed separately in the order; reasonable compensation was considered within overall discretion.	Yes; the district court must separately account for guardian ad litem fees.

Brunzell v. Golden Gate National Bank, 85 Nev. 345, 455 P.2d 31 (Nev. 1969) (establishes factors for reasonable attorney fees in Nevada)
Shuette v. Beazer Homes Holdings Corp., 121 Nev. 837, 124 P.3d 530 (Nev. 2005) (limits and directs discretion in fee awards; Brunzell factors guidance)
Mainor v. Nault, 120 Nev. 750, 101 P.3d 308 (Nev. 2004) (reasonableness standard for settlements involving minors)
Robidoux v. Rosengren, 638 F.3d 1177 (9th Cir. 2011) (special duty to safeguard minors’ interests; independent evaluation)
In re Abrams & Abrams, P.A., 605 F.3d 238 (4th Cir. 2010) (district court may review attorney fees for reasonableness)