Dahlke v. Dahlke, 351 P.3d 937

After a 2010 divorce, the parties shared custody roughly one-half of each month.
In September 2018, Father petitioned to modify custody alleging a material change in circumstances.
Mother counterclaimed for primary custody; trial involved in-camera child remarks.
The district court found a material change and awarded Mother primary custody with liberal visitation for Father.
Father works a 12-hour rotating shift; his home includes several children, affecting privacy for AD and ED.
Mother owns a three-bedroom home, with AD and ED having private bedrooms when in her custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there a material change warranting reopening custody?	Dahlke argues only Mother's arrest mattered.	Dahlke contends the court could reopen for multiple changes.	Yes; material change supported reopening the custody order.
Was the best-interests custody award to Mother an abuse of discretion?	Dahlke asserts court ignored stability concerns and weight of arrest and living situation.	Dahlke claims court overemphasized Mother's arrest and stepfamily dynamics.	No; court thoroughly weighed best-interests factors and did not abuse discretion.

Gurney v. Gurney, 899 P.2d 52 (Wyo. 1995) (permits reopening upon material change in circumstances)
CLH v. MMJ (In re TLJ), 129 P.3d 874 (Wyo. 2006) (jurisdiction to modify exists after material change)
Pace v. Pace, 22 P.3d 861 (Wyo. 2001) (discretion in custody assessments; welfare of children paramount)
Reavis v. Reavis, 955 P.2d 428 (Wyo. 1998) (balancing parental rights with children's needs)
Love v. Love, 851 P.2d 1283 (Wyo. 1993) (child's custodial preference is a factor to consider)
Roberts v. Vilos, 776 P.2d 216 (Wyo. 1989) (factors for weighing child's preference and welfare)
In re Adoption of ADA, 132 P.3d 196 (Wyo. 2006) (district court weighs evidence and credibility in custody)
Aragon v. Aragon, 104 P.3d 756 (Wyo. 2005) (district court weighs evidence; custody determinations defer to trial judge)