JCLK k/n/a JCLS v. ZHB, 353 P.3d 720

BHB is a four-year-old born May 2010 in Cheyenne, Wyoming; Mother and Father were never married but Father is BHB’s biological parent.
Father filed in October 2010 to establish paternity, custody, visitation, and child support; he also sought a mutual restraining order.
Case activity was limited until July 2013 when the district court noted imminent dismissal for inactivity; trial held August 28, 2014.
At trial, BHB had primarily lived with Mother; Mother was then living with her husband in Shoshoni, with several half-siblings in the household.
Father lived in Cheyenne with stable employment and National Guard service, seeking more contact and support for BHB.
The district court awarded primary custody to Father after weighing the § 20-2-201 factors; Mother appeals alleging error in separating BHB from half-siblings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court abuse its discretion in awarding primary custody to Father?	Mother contends separation from half-siblings was unjust and not properly explained.	Father argues best interests supported custody award to him despite separation from half-siblings.	No abuse of discretion; detailed § 20-2-201 analysis supports award.

Dowdy v. Dowdy, 864 P.2d 439 (Wy. 1993) (separation of siblings considered among best-interests factors)
Rogers v. Rogers, 973 P.2d 1118 (Wy. 1999) (separation of siblings is a factor among many in best interests)
Pace v. Pace, 22 P.3d 861 (Wy. 2001) (court must explain on the record if separating siblings; scrutinized custody split)
Aragon v. Aragon, 104 P.3d 756 (Wy. 2005) (reaffirmed need to explain basis for separating siblings; public policy in preserving sibling relationships)
Noonan v. Noonan, 122 P.3d 964 (Wy. 2005) (no complete record on sibling separation; remanded for insufficient findings)
Arnott v. Arnott, 293 P.3d 440 (Wy. 2012) (best interests are paramount; court must weigh all evidence)