Landon Gregory Greer v. Alba Rosy Greer, 2017 WY 35

Parents divorced in 2014 in Cody, Wyoming; Mother awarded primary physical custody and Father liberal visitation (including six consecutive weeks during Father’s slow season).
Mother struggled to find work in Cody, moved with the children to Arizona after notifying Father, and filed to modify visitation; Father cross-filed to modify custody and sought contempt.
Mother initially faced a background-check barrier for a government job but obtained a substitute-teaching position and later a permanent offer; she testified the move was to obtain employment and avoid insolvency.
The parties live over 1,000 miles apart; Father remarried and has a larger blended household; travel for visitation involves airline+car and scheduling conflicts with school calendar.
District court found a material change of circumstances, applied statutory best-interest factors and Arnott relocation considerations, retained Mother as primary custodial parent, adjusted visitation, ordered Mother to share travel costs, and declined to hold her in contempt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion by keeping custody with Mother after relocation	Father: move unjustifiably reduced his visitation; custody worked in Cody; Mother moved hoping to find work and shouldn’t remain custodial	Mother: moved to obtain viable employment to support children; was primary caregiver; move was in children’s best interests	Court: No abuse of discretion; upheld Mother as primary custodian after weighing §20-2-201 factors and Arnott relocation factors
Whether district court abused discretion by refusing to hold Mother in contempt for interfering with visitation	Father: Mother’s move prevented him from exercising decree-ordered visitation; seeks contempt	Mother: complied with notice requirements; decree did not prohibit out-of-state move; move was for legitimate employment needs	Court: Affirmed refusal to hold contempt; record insufficient to show which contempt claimed, no decree violation shown, and procedural/record defects prevented review

Arnott v. Arnott, 293 P.3d 440 (Wyo. 2012) (relocation may be a material change; courts must balance factors without presumptions)
Tracy v. Tracy, 388 P.3d 1257 (Wyo. 2017) (abuse-of-discretion standard for custody modifications)
Roemmich v. Roemmich, 238 P.3d 89 (Wyo. 2010) (standard for reviewing custody, visitation, and support modifications)
Tropea v. Tropea, 665 N.E.2d 145 (N.Y. 1996) (relocation cases are particularly fraught and require careful balancing)
Weidt v. State, 312 P.3d 1035 (Wyo. 2013) (indirect criminal contempt requires separate criminal proceeding)
Stephens v. Lavitt, 239 P.3d 634 (Wyo. 2010) (distinguishing civil and criminal contempt standards)
Watt v. Watt, 971 P.2d 608 (Wyo. 1999) (prior rule that change of residence alone is not necessarily a material change; later addressed by Arnott)