TSR v. State of Wyoming (Wyoming 2017)

As long as the process meets statutory requirements, a court may deviate from presumptive support for later-born children. The mother appealed the district court’s decision to deviate downward from presumptive support for a child born of the father’s current marriage. The district court calculated presumptive support for the parties’ child. The court then calculated the support amount for two children, the second child being the later-born child. Wyo. Stat. Ann. § 20-2-37 provides a deviation for the responsibility of either parent for the support of other children, whether court ordered or otherwise. The court applied this provision and ordered support as the father’s share of the amount for two children. The Supreme Court upheld the decision. It found the Court followed the statutory procedure and made the correct findings.