Jason William Stephen v. Amy Jo Stephen, 355 P.3d 1228

Husband appeals the property division in a Wyoming divorce, challenging the lump-sum payment and valuation method.
Husband owns 60% and his father 40% of Gateway Construction, a residential construction company.
Husband receives a guaranteed $2,000 weekly remuneration plus benefits; tax draws were taken from the business capital account.
Wife stayed at home and contributed to the marriage’s success; she sought compensation reflecting her nonfinancial contributions in the business value.
Experts valued the business using different methods; Wife’s expert used capitalization of earnings (higher value) and Husband’s used several methods including marketable capitalization with a discount.
The district court valued the business via Wife’s expert, ordered a lump-sum payment, and gave the parties an opportunity to negotiate a payment schedule (which they could not agree to). The court eventually imposed a lump-sum and final orders.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether lump-sum payment was proper or should be paid over time.	Husband argues for staged payments and requires a hearing on ability to pay.	Wife contends lump sum is fair given income, business profitability, and access to funds; parties failed to agree on schedule.	Lump sum payment affirmed.
Whether capitalization of earnings was appropriate without survivability finding.	Husband claims survivability should be established before using that method.	Wife argues the court may use capitalization of earnings regardless of survivability finding if fair.	Court-approved capitalization of earnings method; no abuse.
Whether a minority discount should have been applied.	Husband contends a minority discount should have been used.	Wife’s expert testified discount not appropriate because no sale was contemplated.	No minority discount applied; trial court discretion upheld.

Bailey v. Bailey, 954 P.2d 962 (Wyo. 1998) (remanded for guidance on equitable cash payment structuring when lump sum may be unfair)
McLoughlin v. McLoughlin, 996 P.2d 5 (Wyo. 2000) (limits remand when cash payment can be met without hardship; assesses ability to pay)
Bagley v. Bagley, 2013 WY 126, 311 P.3d 141 (Wy. 2013) (affirms trial court’s discretion in property division and payment structure)