MR v. State, 2015 WY 79

The juvenile court in Park County revoked a consent decree in an educational neglect case due to an alleged violation by Mother of the decree's terms; Father MR appealed the revocation.
The child was twelve, in sixth grade, and the neglect petition (filed May 24, 2013) alleged Parents failed to provide adequate education.
A guardian ad litem and separate counsel for each parent were appointed; an MDT participated and the parties entered an Agreement in Support of Consent Decree on July 11, 2013.
The decree required the parents to obtain an alcohol/substance abuse evaluation and follow the recommended treatment; it allowed reinstatement of neglect proceedings if the decree was violated.
Mother underwent multiple evaluations (Nov 2013 and Feb 2014) with evolving treatment recommendations; she completed a 30‑day inpatient program and began outpatient therapy.
State motions to revoke the decree were filed in June 2014 after Mother’s alcohol use; the court revoked the decree on July 16, 2014, finding educational concerns addressed but Mother violated the decree; the court then reinstated neglect proceedings and ordered dispositions, prompting Father’s timely appeal in September 2014.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the juvenile court lose jurisdiction after finding educational concerns addressed?	Father argues that once addressed, the court loses jurisdiction.	Mother contends that the decree and statutory framework permit continued jurisdiction.	No; court could retain jurisdiction to enforce or reinstate if violations occurred.
Did the court err in finding that Mother violated the consent decree by drinking?	Father contends the decree language did not expressly prohibit drinking.	Mother argues the decree required treatment, not lifelong abstention; relapse did not breach a clear term.	Yes; the court erred by construing the decree to prohibit drinking without explicit language.

Harmon v. Star Valley Medical Center, 2014 WY 90 (Wy. 2014) (statutory interpretation governs use of plain meaning)
MF v. State, 2013 WY 104 (Wy. 2013) (de novo review of jurisdictional statutes)
In re Mark E. Dowell Irrevocable Trust #1, 2012 WY 154 (Wy. 2012) (contract interpretation de novo standard)
Bowers Oil and Gas, Inc. v. DCP Douglas, LLC, 2012 WY 103 (Wy. 2012) (plain meaning governs contract interpretation; extrinsic evidence limited)
Hunter v. Reece, 2011 WY 97 (Wy. 2011) (contract interpretation and ambiguity standard for unambiguous terms)
Herling v. Wyoming Machinery Co., 2013 WY 82 (Wy. 2013) (courts refrain from rewriting contracts to supply missing terms)