Zupan v. Zupan (Wyoming 2016)

The parent who petitions to modify a stipulated child support order must show a material change in circumstances as well as a 20 percent change in the support amount. This rule addresses the issue of a parent agreeing to a support amount 20 percent lower or higher than the presumptive amount only to petition for a modification as soon as possible based solely on a 20 percent change in the support amount. In this case, the mother alleged a change in custody which satisfied the change in circumstances requirement.