Bruce v. Bruce (Wyoming 2021)

The trial court’s child support order will not be disturbed absent an abuse of discretion. The parents divorced. The final decree ordered the father pay child support for the child and half of the travel expenses. The father appealed the order arguing the court should have attributed a higher income to the mother, erred in awarding retroactive support and in denying a deviation for travel expenses. The Supreme Court affirmed the order. The mother’s income was consistent with her financial affidavit and testimony at trial. She attached sufficient documentation to her financial affidavit and the father offered no proof that any missing documentation would change the income calculation. The trial court properly excluded a means tested source of income from the mother’s income. The trial court was well within its discretion to award support back to final day of the custody trial. The final order appropriately split the travel costs. The temporary order granted him a deviation but he was responsible for all travel costs during that time.