Brown v. BrownAnnotate this Case
The Supreme Court affirmed the order of the district court modifying Father's child support obligation to Mother, holding that the court did not err by modifying Father's child support obligation without requiring Mother to prove a material change in circumstances in addition to a twenty percent change in the support amount.
Father commenced this action in 2019 seeking modification of child custody, visitation, and support. The parties reached an agreement on all matters in Father's petition except child support, which proceeded to trial. Applying the child support guidelines, the district court found Father's presumptive support obligation would change by more than twenty percent from the amount previously ordered in 2016, establishing a change in circumstances to justify a modification under Wyo. Stat. Ann. 20-2-311(a). The Supreme Court affirmed, holding that the heightened requirement for modification of a child support order was inapplicable and that Mother's showing of a twenty percent change in support justified the district's modification of Father's child support obligation.