Bishop v. Bishop, 404 P.3d 1170

Parents divorced in 2014; Father awarded primary physical custody of the child (born 2011); Mother retained liberal visitation.
Multiple post-decree contempt filings (eleven motions) arising from repeated visitation disputes.
Father repeatedly denied Mother visitation (including a seven‑month unilateral refusal), claiming safety concerns because Mother’s boyfriend is a registered sex offender; the district court previously found no danger from the boyfriend.
The child began counseling for anxiety and difficulty transitioning between households; parents attended court‑ordered parenting classes without resolving acrimony.
District court found Father in contempt several times and granted Mother’s petition to modify custody, awarding primary physical custody to Mother while continuing joint legal custody and liberal visitation to Father.

Issue	Plaintiff's Argument (Father)	Defendant's Argument (Mother)	Held
Whether there was a material change in circumstances since the decree	Father: No material change; his visitation denials were justified by safety concerns about Mother’s boyfriend	Mother: Repeated, unreasonable denial of visitation and child’s counseling needs show material change affecting welfare	Court: There was a material change — prolonged denial of visitation, child’s anxiety, parental acrimony, Mother’s stabilized circumstances justified reopening custody order
Whether modification was in the child's best interests	Father: Transfer would harm child (counselor said timing may impede development; child upset about arrest, bed at Mother’s)	Mother: Father’s contempt and interference harm child’s relationship with Mother; Mother’s stable home, sibling bond, and willingness to foster Father–child relationship favor Mother	Court: Modification to award Mother primary physical custody was in child’s best interests (considered statutory factors; Father’s interference weighed heavily)

Gjertsen v. Haar, 347 P.3d 1117 (Wyo. 2015) (standard of appellate review for custody modification)
Hanson v. Belveal, 280 P.3d 1186 (Wyo. 2012) (two‑step inquiry: material change then best interests)
In re TLJ, 129 P.3d 874 (Wyo. 2006) (burden to show material change; evaluate current vs. prior circumstances)
Shindell v. Shindell, 322 P.3d 1270 (Wyo. 2014) (criticizing unilateral denial of visitation; contempt consequences)
Russell v. Russell, 948 P.2d 1351 (Wyo. 1997) (custodial parent’s undermining of other parent harms child’s welfare)
Aragon v. Aragon, 104 P.3d 756 (Wyo. 2005) (sibling‑preservation as a factor in custody decisions)