June 2020 | 2020 WY 78 (2020)

Van Fleet v. Guyette (Wyoming 2020)

A parent can’t disregard a statutory requirement then complain about its outcome. This matter came before the court on a modification of custody. With respect to child support, the court ordered both parents to file a financial affidavit. The mother filed hers along with supporting information. The father didn’t, and the court found him in contempt. The contempt order gave him an additional opportunity to file the affidavit. Otherwise, the mother was directed to file an affidavit of imputed income and allege his income. The mother’s attorney did so, and the court ordered support accordingly. The father appealed the child support order, arguing the trial court shouldn’t have imputed income based on an affidavit from the mother’s attorney. The Supreme Court affirmed the order, noting the father failed to file a financial affidavit as ordered. A party can’t disregard a requirement then complain about the outcome. The father didn’t cite to any authority that the affidavit had to come from the Mother.

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