Long v. Long, 413 P.3d 117

Husband and Wife separated after long marriage with four children; Wife (stay-at-home RN) sought divorce; Husband earned high income until a 2015 layoff.
On August 7, 2015, Wife presented a lawyer-drafted stipulated judgment and decree allocating property, awarding Wife sole legal custody, setting visitation "at Mother's discretion," child support $3,025/month, and alimony $3,000/month; both signed before a notary.
Wife filed for divorce in September 2015 and submitted the stipulation to the district court; Husband later objected and contested enforceability alleging intoxication, coercion, reading/comprehension problems, unconscionability, and inequitable property/debt, custody, support and alimony terms.
District court held a hearing, found the stipulation was an enforceable contract supported by consideration, not procured by coercion or incompetence, and incorporated it as the final decree except it kept an earlier circuit-court child support order ($2,500 + $500 arrearage).
Husband appealed. The Supreme Court affirmed enforceability as to consideration, property/debt division, and alimony, but remanded custody, visitation, and child-support matters for further findings and compliance with statutory requirements.

Issue	Husband's Argument	Wife's Argument	Held
Enforceability / consideration	No consideration because stipulation signed before divorce complaint filed; thus no claims to settle	Settlement of separation claims between separated spouses supplies consideration	Affirmed: settlement of marital claims (separation agreement) supplies consideration; valid contract
Unconscionability	Agreement grossly favors Wife and Husband lacked meaningful choice (signed to try to reconcile; dyslexia; intoxicated)	Although lop-sided, Husband freely agreed and could have sought counsel; not procedurally unconscionable	Affirmed: substantive imbalance found but no procedural unconscionability — Husband had meaningful choice
Property & alimony distribution	Division is not "just and equitable"; alimony unsupported by findings of need or ability to pay	Parties stipulated to terms; courts routinely enforce settlement provisions including alimony	Affirmed as to property and alimony: stipulation controls; no additional findings needed for agreed alimony
Child custody, visitation & child support	Custody, vague visitation, and child support enforcement improper without best-interest findings, detailed visitation schedule, and presumptive child-support findings	Stipulation governs these terms	Reversed/remanded: district court must make best-interests findings on custody, craft an enforceable detailed visitation schedule, and state presumptive child-support amount or justify deviation

Combs v. Sherry-Combs, 865 P.2d 50 (Wyo. 1993) (distinguishes prenuptial, postnuptial, and separation agreements; identifies consideration rules)
Lipps v. Loyd, 967 P.2d 558 (Wyo. 1998) (settlement of claims between separated spouses is sufficient consideration)
Redland v. Redland, 288 P.3d 1173 (Wyo. 2012) (standard of review de novo for pure legal questions)
Kindred Healthcare Operating, Inc. v. Boyd, 403 P.3d 1014 (Wyo. 2017) (de novo review for unconscionability; discussion of contractual freedom)
Pittard v. Great Lakes Aviation, 156 P.3d 964 (Wyo. 2007) (factors for procedural and substantive unconscionability)
Roussalis v. Wyoming Medical Center, Inc., 4 P.3d 209 (Wyo. 2000) (approach to unconscionability balancing test)
David v. David, 724 P.2d 1141 (Wyo. 1986) (court must still make just and equitable property dispositions despite settlements)