Windham v. Windham
Annotate this CaseIn 2012, the parties divorced. The original divorce decree provided for joint legal and physical custody of the parties’ three children. In 2013, Father field a petition to modify custody, visitation and support. The district court granted Father sole custody, modified the visitation schedule, and required Mother to pay child support in an amount less than the statutory presumptive amount. The district court also awarded expenses under Wyo. R. Civ. P. 37 incurred by Mother’s pro bono attorney and denied Father’s Wyo. R. Civ. P. 11 motion for sanctions against Mother for seeking attorney’s fees and expenses for discovery violations. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it (1) deviated from Mother’s presumptive child support obligation; (2) authorized the award of expenses under Rule 37 that were not incurred by Mother; and (3) denied Father’s Rule 11 motion for sanctions.
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