Martin v. Hart, 429 P.3d 56

Mother (Heather Martin) awarded primary physical and legal custody after Father's (Christopher Hart) paternity petition; parties live ~Wyoming (Mother) and Arizona (Father).
Temporary stipulation provided limited monthly visitation; Father often missed visits due to travel cost and scheduling and had not had overnight custody before trial.
District court adopted a graduated monthly visitation plan (7–14 consecutive days monthly as child ages), expanded summer visits, alternating holidays, complex travel/expense allocation options, and directed parties to seek modification once the child starts kindergarten.
The court deviated downward from presumptive statutory child support and ordered Father to pay $450/month without stating the presumptive amount or adequate financial findings.
Mother timely appealed the custody/visitation terms, travel allocation, and the child support determination; the Supreme Court found the visitation and child support orders were an abuse of discretion and remanded.

Issue	Mother (Plaintiff) Argument	Father (Defendant) Argument	Held
Jurisdiction to hear appeal	Timely appealed final Order of Paternity, Custody, Visitation, and Support	Clarification hearing rulings are non-appealable guidance, not final orders	Court has jurisdiction — Mother appealed the appealable order within 30 days
Graduated visitation requiring extensive travel	Plan destabilizes a very young child, effectively undermines Mother’s primary custody, and requires excessive travel	Plan facilitates Father’s relationship given distance; court may order unconventional schedules	Visitation order abused discretion: imposed instability, failed to explain/support travel burden and expectations of cooperation; reversed and remanded
Failure to specify how custody/visitation will work when child starts school	Court left future school-age arrangement open, undermining stability and statutory requirement for definite orders	Parties can agree later or return to court with modification	Abuse of discretion: order must specify how visitation/custody will change as child ages; remanded for a defined long-term plan
Child support deviation	Deviation unjustified: court failed to state presumptive amount, omitted relevant financial findings and cost evidence	Deviation justified by Father’s support of another child and insurance obligations	Abuse of discretion: court failed to state presumptive support and relied on unreliable income figures; remand for proper findings and evidence collection

Bruegman v. Bruegman, 417 P.3d 157 (Wyo. 2018) (shared custody considered equally; orders must be tailored to child’s age)
Buttle v. Buttle, 196 P.3d 174 (Wyo. 2008) (court must provide stable, well‑defined custody terms; remand if left open-ended)
Reavis v. Reavis, 955 P.2d 428 (Wyo. 1998) (court abused discretion when failing to explain sweeping custody changes)
Moss v. Moss, 156 P.3d 316 (Wyo. 2007) (child support order reversed where presumptive amount not stated and findings insufficient)
Long v. Long, 413 P.3d 117 (Wyo. 2018) (court must state presumptive support and explain deviations)
Windham v. Windham, 348 P.3d 836 (Wyo. 2015) (standards for reviewing child support deviations)
Keck v. Jordan, 180 P.3d 889 (Wyo. 2008) (abuse of discretion standard explained for support deviations)
Williams v. Williams, 368 P.3d 539 (Wyo. 2016) (stability is paramount in custody determinations)