Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed the district court’s final order granting primary custody of the parties’ children to Father but reversed the court’s contempt finding against Mother.Father filed a petition seeking to modify the custody, visitation, and child support provisions of his divorce decree. After an evidentiary hearing, the district court, on its own motion, entered a temporary custody modification order, which was, in effect, a trial coparenting plan that would become permanent unless either parent requested a new hearing to establish that it was unworkable. Father filed such a motion. The district court held a second evidentiary hearing and then entered a final order granting primary custody of the children to Father. The court then held Mother in contempt of court for violating certain terms of the initial temporary order. The Supreme Court affirmed in part and reversed in part, holding (1) although the district court abused its discretion when it entered the temporary custody order, the permanent custody modification was not an abuse of discretion; and (2) the district court abused its discretion when it held Mother in contempt of court and improperly factored Mother’s contempt into her contempt motion against Father. View "Swan v. Swan" on Justia Law

The Supreme Court affirmed in part and remanded in part the final decree of divorce entered by the district court in this case.Before Wife filed for divorce from Husband, the parties executed a stipulated judgment and decree of divorce establishing property distribution, child support, child custody and visitation, and alimony. The Supreme Court held (1) the district court correctly found that the stipulated decree was a valid agreement between Husband and Wife that was supported by consideration, and the stipulated decree was not unconscionable; (2) the district court appropriate enforced the order in the divorce decree with respect to the property, debt distribution, and alimony; but (3) the district court erred in enforcing the order with respect to child custody, visitation, and child support. View "Long v. Long" on Justia Law

In this dispute over Plaintiffs’ right to prepay a contract for deed and Defendant’s obligation to deliver the deed, the Supreme Court affirmed the district court’s rulings in favor of Plaintiffs. The district court ruled in favor of Plaintiffs and ordered Defendant to pay attorney fees and costs for discovery violations. The Supreme Court agreed with Plaintiffs’ statement of the dispositive issues, holding (1) Defendant's appeal of the declaratory judgment ruling was untimely; (2) the district court properly awarded fees and costs for failure to present cogent argument or pertinent authority; and (3) Plaintiff should be awarded sanctions pursuant to Wyo. R. App. P. 10.05. View "Byrnes v. Harper" on Justia Law

The Supreme Court affirmed the juvenile court’s order altering the plan for permanent placement for two boys from reunification of the family to termination of Father’s parental rights and adoption. Specifically, the Supreme Court held (1) Father did not avail himself of the efforts made by the Wyoming Department of Family Services (DFS) to reunify the family; and (2) therefore, the juvenile court did not abuse its discretion when it determined that the DFS made reasonable, but unsuccessful, efforts to supply Father with such services as might enhance his chances at reunification with his sons and that the permanency plan for the children should accordingly be changed to adoption. View "TW v. State" on Justia Law

The Supreme Court affirmed the district court’s order, entered after a jury trial, terminating Father’s parental rights to his infant daughter. The court held (1) the evidence in this case was clear and convincing and allowed the jury reasonably to find that Appellant was not a fit parent under the provisions of Wyo. Stat. Ann. 14-2-309(a)(iv); and (2) the Department of Family Services failed to comply its rule establishing deadlines for completing a case plan, but the error was harmless, and therefore, the district court did not err when it denied Father’s motion for judgment as a matter of law. View "Anastos v. State, Department of Family Services" on Justia Law

The Supreme Court affirmed the decision of the district court requiring Wife to return certain personal property Husband after the divorce decree’s ninety-day deadline.On appeal, Wife argued that, by allowing Husband to recover property after the divorce decree’s ninety-day deadline, the district court improperly modified the parties’ property settlement without the required written agreement. The settlement declared that no modification or waiver of the terms of the agreement shall be valid unless in writing. The Supreme Court affirmed, holding that the district court did not modify the parties’ agreement, but rather, the parties modified the agreement on their own, and the district court approved the modification. View "Acton v. Acton" on Justia Law

The Supreme Court affirmed the order of the district court modifying child support with respect to Mother’s daughter. In 2011, Mother and Father entered into an agreement modifying Father’s child support obligation. Approximately five years later, at Mother’s request, the Child Support Enforcement Program filed a petition to modify Father’s child support obligation. The district court entered an order modifying child support but granted a downward deviation from the presumptive child support. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by using the matrix for two children rather than one child when it calculated a deviation from the presumptive child support; and (2) properly made specific findings in its order for the reasons it granted a deviation pursuant to Wyo. Stat. 20-2-307(b). View "TSR v. State, ex rel., Department of Family Services" on Justia Law

The Supreme Court affirmed the order of the district court striking RB’s appearance in the underlying adoption action and granting the foster parents’ petition for adoption of SSO, the biological son of RB. The adoption court determined that RB’s parental rights had previously been terminated, and therefore, RB had no standing to enter an appearance in the adoption case or to challenge the adoption. RB appealed the order granting the foster parents’ motion to strike his entry of appearance and objection to SSO’s adoption, and of the adoption order. The Supreme Court held (1) the district court properly struck RB’s appearance in the adoption action; and (2) because RB’s parental rights have been terminated, RB had no standing to object to or otherwise participate in the adoption. View "In re Adoption of SSO" on Justia Law

The Supreme Court affirmed the juvenile court’s order denying Appellants’ motion to intervene in custody proceedings relating to their granddaughter, EHD. The court held (1) in light of the facts of this case, the juvenile court did not abuse its discretion in denying Appellants’ request to intervene; and (2) Appellants did not have standing to pursue their remaining arguments that the juvenile court abused its discretion in denying Appellants’ requests to be appointed to the multi-disciplinary team and in denying Appellants’ request that EHD be placed with them. View "MMH v. State" on Justia Law

In this appeal brought by Mother, the Supreme Court affirmed the divorce decree entered by the district court. The court held (1) the district court did not abuse its discretion in awarding Father primary physical custody of the parties’ daughter; (2) the district court did not abuse its discretion when it denied Mother’s motion to bifurcate the trial to separate the property distribution proceedings from child custody and support proceedings; and (3) this court declines to award sanctions under Wyo. R. App. P. 10.05(b), which authorizes the court to certify that there was no reasonable cause for an appeal and award attorney’s fees and damages. View "Ransom v. Ransom" on Justia Law