September 2014 | 161 P.3d 515 (Wyo. 2007)

Starkey v. Starkey (Wyoming 2007)

Father does not receive credit for an overpayment of his child support obligation. Statutes and case law indicate a clear aversion to the unilateral modification of child support orders. The circumstances did not warrant application of the exception to the general rule because (1) the father overpaid the obligation intentionally and voluntarily, (2) the mother never asked the father for the extra payments, nor did his daughter, (3) the father unilaterally modified that obligation without court approval, and (4) it was the father’s obligation to pay the specified amounts according to the decree, and orders modifying it thereafter.

Starkey v. Starkey.pdf

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