Nested models and parent validation
This will probably work for you, but I have a feeling there's a much better answer out there. It sounds like a bug to me.
class Parent < ActiveRecord::Base
validate :must_have_children
def must_have_children
if children.empty? || children.all?(&:marked_for_destruction?)
errors.add(:base, 'Must have at least one child')
end
end
end