Knezovich v. Knezovich, 340 P.3d 1034

Parties divorced in 2004; Mother awarded primary custody, Father ordered to pay $400/month child support.
In June 2011 Father petitioned to modify custody; Mother counter-petitioned for modification of child support.
Final hearing occurred in August 2013; custody/visitation largely resolved, leaving only support and medical expenses for dispute.
District court imputed Mother’s net income to $2,100/month due to voluntary underemployment after she started a photography business.
Court ordered Father’s modified support retroactive to June 2011 and set arrears at $12,971.88, payable at $100/month, while noting Mother was underemployed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused discretion in determining Mother's income.	Knezovich argues the court erred in imputing income.	Mother contends income should reflect actual earnings and deductions.	No reversible abuse; record insufficient for review.
Whether the district court abused discretion in retroactively modifying support.	Knezovich asserts retroactivity was improper.	Mother argues retroactivity is allowed under statute.	Auto-retroactivity permitted; but review limited by absent transcript record.

Barrett-Oliver v. Quast, 302 P.3d 909 (Wy. 2013) (child support discretion guided by district court rulings)
Arnold v. Day, 158 P.3d 694 (Wy. 2007) (record on appeal essential for review)
Lykins v. Habitat for Humanity, 237 P.3d 405 (Wy. 2010) (absence of transcript requires presumption of regularity)
Ready v. Ready, 76 P.3d 836 (Wy. 2003) (district court discretion in child support matters)
Walker v. Walker, 311 P.3d 170 (Wy. 2013) (retroactive modification of support reviewed for abuse of discretion)