Booth v. Booth, 432 P.3d 902

Parents divorced in 2015; Mother received primary physical custody and possession of the Oakley, Utah marital home; Father lived in Rock Springs, Wyoming. The divorce decree required Father to exercise visitation at the Oakley home.
Father had alternating weekend visitation, Tuesday evenings, spring break in odd years, and four consecutive weeks in summer; Father paid $1,500 toward the mortgage and transportation for visits.
The on-site visitation arrangement generated ongoing conflict; Father was held in contempt for failing to vacate the Oakley home and for having guests there.
In 2017 Father petitioned to modify the decree, seeking to exercise visitation at a location of his choosing (citing distance and midweek visit infeasibility); Mother agreed the Oakley-location arrangement was not working but wanted visits in Summit County.
At the modification hearing the court (on its own initiative) suggested a more "normalized" schedule, excluding Oakley, splitting travel costs, giving Father most of the summer and all spring breaks; the written order adopted those changes.
Mother appealed, arguing (among other things) the court exceeded its authority by altering the visitation schedule without findings that the new schedule was in the children’s best interests.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (Father)	Held
1. Did court violate due process by modifying visitation schedule beyond relief requested?	Mother: No adequate notice; Father didn't request expanded summer/spring time.	Father: Petition sought modification of visitation and raised travel/distance problems; parties discussed broader changes at hearing.	Court: No due process violation; Mother had notice and opportunity to be heard.
2. Was there a material change in circumstances to reopen visitation issues?	Mother: Change was limited to location, not schedule.	Father: Longstanding conflict and interference made Oakley-visitation unworkable; midweek visits infeasible.	Court: Material change existed (parental animosity, contempt history) sufficient to reopen visitation.
3. Did court abuse discretion by modifying visitation without best-interest findings?	Mother: Yes; record and order lack findings applying §20-2-201(a) factors to justify new schedule.	Father: Argued for more normalized schedule (half summer); consented generally to change of location.	Court: Abused discretion—reversed visitation-schedule modifications because record lacks findings/evidence that expanded spring/summer time is in children's best interests.

Kappen v. Kappen, 341 P.3d 377 (Wyo. 2015) (material-change test for custody modification)
Martin v. Hart, 429 P.3d 56 (Wyo. 2018) (abuse-of-discretion review and need for articulated reasoning in unconventional arrangements)
KC v. State, 351 P.3d 236 (Wyo. 2015) (due process: notice and opportunity to be heard)
Reavis v. Reavis, 955 P.2d 428 (Wyo. 1998) (trial judge should place crucial reasons on the record to allow review)
Meehan-Greer v. Greer, 415 P.3d 274 (Wyo. 2018) (reversal where court exceeded requested relief and record lacked best-interest support)
Forbes v. Forbes, 672 P.2d 428 (Wyo. 1983) (court not bound by parties' stipulation; must determine children's welfare)