March 2018 | 2018 WY 26 (2018)

Long v. Long (Wyoming 2018)

A district court must include the presumptive child support amount in a final decree of divorce. That is the basis for any deviation. Prior to the divorce, the mother filed for a protective order in Circuit Court, and the court set support in this action. The District Court incorporated the amount of support in the final decree. The father appealed arguing that the support amount was not supported by a financial affidavit. The Supreme Court found that the court had sufficient information about the father’s income to establish support. The father chose not to provide a financial affidavit and that he shouldn’t benefit from his disregard of the statute. However, the Supreme Court found that the decree did not set out presumptive support, and the Circuit Court order also did not contain this information. The Court remanded the case for additional findings.

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