Family Law Cases
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Family Law

WyomingAppellate ProcedureFamily LawParental Rights
Wyoming Supreme Court
Uncategorized

Keller & Cruz v. Wyoming DFS — Section 14-2-309(a)(v) Requires No Reunification Efforts Finding, and DFS Procedural Gaps Do Not Defeat Termination Unless They Impair a Parent’s Fundamental Rights

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The Wyoming Supreme Court affirmed the termination of both parents’ parental rights to three children under Wyo. Stat. Ann. § 14-2-309(a)(v), holding that the statute—requiring only that the child has been in foster care for 15 of the past 22 months and that the parent is unfit—does not impose a reasonable-reunification-efforts requirement; that DFS’s documentation gaps did not reach the structural failure level required by MB; and that clear and convincing evidence of parental unfitness supported the district court’s termination order.

WyomingAppellate ProcedureChild Custodydomestic-violence
Wyoming Supreme Court
Uncategorized

Idler — Divorce Appeal Summarily Affirmed Where Counsel’s Briefs Lacked Cogent Argument

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The Wyoming Supreme Court summarily affirmed a divorce decree granting Mother sole custody of ten children and assigning nearly all marital debt to incarcerated Father, holding that Father’s nine-issue opening brief contained no cogent argument — just general legal principles with no case-specific analysis — and that his reply brief improperly raised four new issues while failing to respond to Mother’s arguments. Attorney fees under W.R.A.P. 10.05 were declined as a matter of discretion, but costs were awarded.

WyomingChild CustodyCivil ProcedureFamily Law
Wyoming Supreme Court
Uncategorized

Ribera v. Ribera — Wyoming Supreme Court Affirms Divorce Decree on Custody, Property Division, and Rule 35 Motion

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The Wyoming Supreme Court affirmed a Park County divorce decree awarding Mother primary custody and $624,500 in equitable distribution, holding that Father’s W.R.C.P. 35 motion for psychological evaluations was untimely and lacked good cause, that the district court properly reached assets Father transferred to his nonprofit during the proceedings under the badges-of-fraud doctrine from Breitenstine, and that Father was barred by invited error from challenging the shared custody arrangement for the family dog.

WyomingAppellate ProcedureConstitutionalFamily Law
Wyoming Supreme Court
Uncategorized

In re: AC and BI — Juvenile Court’s Mid-Hearing Cure Satisfies Due Process When Pro Se Parent Declines Opportunity to Cross-Examine

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The Wyoming Supreme Court affirmed a child neglect adjudication under plain-error review, holding that a juvenile court’s failure to invite a pro se mother to present opening and closing statements or to cross-examine witnesses was cured mid-hearing when the court three times offered her the opportunity to recall and question any witness—an opportunity she declined.

WyomingAppellate ProcedureEvidenceFamily Law
Wyoming Supreme Court
Uncategorized

In re AC and BI — Wyoming Supreme Court Affirms Neglect Finding, Upholds Admission of Post-Removal Hair Follicle Tests

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The Wyoming Supreme Court affirmed a juvenile court’s finding that Father neglected his two minor children, holding the court did not abuse its discretion in admitting hair follicle test results collected after the date of alleged neglect, because the tests covered the relevant period and any challenge to their probative force went to weight rather than admissibility.

WyomingBreach of ContractFamily Law
Wyoming Supreme Court
Uncategorized

Smerski v. Lemon — Wyoming Supreme Court Reverses Divorce Decree That Misread Postnuptial Agreement on Retirement Account Division

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The Wyoming Supreme Court reversed a divorce decree that treated all retirement accounts listed in postnuptial agreement exhibits as entirely separate property. The court held that the agreement’s express exclusion of retirement accounts from its “separate property” definition, combined with Paragraph 5(g)’s specific formula dividing pre- and post-June 2017 contributions, required the district court to apply the formula to the listed accounts as well.

WyomingCivil ProcedureFamily Law
Wyoming Supreme Court
Uncategorized

Causey v. Causey — Post-Majority Support Denied Where Physically Disabled Adult Child Earns SSDI and Plans College Despite Ongoing Medical Needs

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The Wyoming Supreme Court affirmed the district court’s denial of post-majority parental support for a physically disabled adult child. Although Son was found to be physically disabled, the court held the evidence supported the finding that he was capable of self-support where he received SSDI, performed daily living activities independently, and planned to pursue college on a merit scholarship.

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