Hehn v. Johnson (Wyoming 2022)

Even in default child support hearings, the district court has an obligation to determine income for both parents. The mother filed for paternity and support. The father was served, but failed to answer, and the clerk entered default. Both parents appeared at the hearing. The father was awaiting sentencing on a criminal charge, so a temporary order was entered. Upon the father’s release, the mother requested a default hearing. Both parents appeared. The district court took no evidence. The final order granted mother custody, set out visitation, and ordered child support based on the mother’s calculation. The mother appealed. Specific to child support, the Supreme Court acknowledged the awkwardness of mother’s appeal. The district court granted her requested relief. However, in default situations, the district court has an obligation to determine income for both parents. The district court made no such effort in this case. The court didn’t require financial affidavits from either parent. The father was present at hearings, but not asked about his income. The case was reversed and remanded for additional proceedings.