Brown v. Brown (Wyoming 2021)

Unless an order contains the required findings, a child support order is assumed to be presumptive support and only requires a change in amount for modification. The original divorce decree ordered the father to pay support. He later filed to modify the divorce decree. The final order modified support based on an increase in the support amount sufficient to meet the required twenty percent change. The father appealed. He argued modification of the order required a substantial change of circumstances above and beyond the change in amount since the original order was stipulated to and deviated from presumptive support. The Supreme Court affirmed the modified order. The original order failed to contain statutory requirements such as the amount of the parents’ incomes and contained no language about a deviation. Without additional language, the Supreme Court concluded the required change in amount was the only thing necessary to modify the order.