Background
Jonathan Causey (Son) was born prematurely and has experienced significant medical challenges throughout his life, including chronic lung injury, immunodeficiency, tachycardia, visual impairment, and general coordination difficulties. He has also been diagnosed with attention deficit disorder, autism spectrum disorder, and depressive disorder, though Son and his mother, Tracey Causey (Mother), limited their petition to Son’s physical disabilities only. Mother and Father divorced in 2020. The divorce decree did not require either parent to pay child support. In 2022, Mother obtained a temporary order requiring Father to pay support through Son’s high school graduation. Son reached the age of majority in December 2023 and graduated high school in June 2024. The district court appointed Mother as Son’s adult guardian after he reached majority.
In July 2024, Son and Mother petitioned for post-majority support under Wyoming Statute § 14-2-204(a)(i), which permits a court to extend a parent’s support obligation past the age of majority for children who are “[m]entally or physically disabled and thereby incapable of self support.” The district court held a bench trial. Son testified that he helps his mother cook and clean, can go to the grocery store, maintains a bank account, pays his share of rent and utilities, and has earned Wyoming’s Hathaway Scholarship for college. Son’s physician testified that while Son might struggle in some employment environments, he could succeed in a less physically demanding job with proper accommodations. Mother testified Son has the physical skills needed for daily living. The district court found Son was “physically disabled” but not “thereby incapable of self-support,” and denied the petition. Son and Mother appealed.
The Court’s Holding
The Wyoming Supreme Court affirmed. Chief Justice Boomgaarden’s opinion reviewed the district court’s findings for abuse of discretion, the standard applicable to child support decisions including post-majority support determinations. Under that standard, the appellate court gives the prevailing party every favorable inference and disregards evidence presented by the unsuccessful party.
The district court’s order was “replete with findings” supporting the capability-of-self-support conclusion. Son receives Social Security Disability Income (SSDI), is computer literate, intends to attend college on the Hathaway Scholarship, and can perform many daily living functions independently — feeding himself, cleaning his apartment, grocery shopping, taking his medications, and maintaining a bank account. The district court also relied on its direct observation of Son at trial: he “was able to appear and participate in a normal manner” and his “testimony was responsive, knowledgeable, and intelligent in all respects.” The Supreme Court found those findings supported by the record and declined to reweigh the evidence.
Son and Mother also argued on appeal that their only burden under § 14-2-204(a)(i) was to prove Son is “physically disabled,” and the burden then shifted to Father to show justification for cessation of support. The Supreme Court declined to reach this argument for two independent reasons: no legal authority was cited for the proposition, and it was not raised before the district court, which had plainly proceeded on the understanding that both disability and incapacity for self-support must be established by the petitioner. Wyoming courts will not consider arguments raised for the first time on appeal unless they are jurisdictional or fundamental in nature.
Key Takeaways
- Wyoming Statute § 14-2-204(a)(i) requires proof of both elements to extend parental support obligations past the age of majority: the child must be “mentally or physically disabled” and “thereby incapable of self support” — a finding that a child is disabled does not automatically trigger continued support if the evidence shows the child can support herself or himself.
- A district court’s post-majority support determination is reviewed for abuse of discretion; the appellate court gives the prevailing party every favorable inference and will not reweigh testimony or substitute its own credibility determinations for the trial court’s, particularly where the district court directly observed the child’s demeanor and capabilities at trial.
- Evidence that a disabled adult child receives SSDI, performs daily living activities independently, maintains a bank account, and has formed plans for further education and employment is sufficient to support a finding of capability for self-support, even where the child faces ongoing medical challenges and may need workplace accommodations.
- Burden-shifting arguments regarding the elements of post-majority support under § 14-2-204 must be raised before the district court to be preserved for appeal; an appellate court will not consider them for the first time, particularly when they are unsupported by citation to legal authority.
Why It Matters
For Wyoming family law practitioners, Causey v. Causey sets a useful baseline for what the “incapable of self-support” prong of § 14-2-204(a)(i) requires. The case confirms that the disability finding and the self-support finding are distinct inquiries, and that a factually sympathetic situation — a young adult with genuine, significant, life-long medical conditions — does not automatically result in extended support if the evidence shows the child can function independently in important respects. The district court’s ability to observe the child directly at trial carries particular weight in this analysis.
Practitioners representing parents seeking post-majority support should build a strong trial record focused squarely on incapacity for self-support — not simply on the existence or severity of disability. Evidence of vocational barriers, inability to maintain consistent employment, dependence on caretakers for basic daily tasks, and inability to manage finances independently will be far more probative than medical diagnoses alone. Conversely, evidence that a child receives government benefits, has educational plans, and performs routine daily activities will weigh heavily against the petitioner regardless of underlying medical severity.