Nurian E. Duncan v. Michael P. Duncan, 2026 WY 44

Mother and Father divorced, and under a 2019 custody order Mother had primary custody of their two daughters. 1
After Mother kicked the older daughter, ID, out in November 2024, Father retrieved ID and took her to Colorado. 2
A temporary-custody hearing ended with the court leaving custody unchanged pending the modification motion, but conflict continued after the Christmas visitation. 3
After a second emergency motion, the court gave Father temporary custody of ID, kept ED with Mother, and later ordered both children to remain where they were for the school year. 4
At the modification trial, both daughters wanted to live with Mother, but the GAL recommended primary custody to Father after analyzing the statutory best-interest factors. 5
The district court found a material change in circumstances and modified custody to place both daughters primarily with Father. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether temporary custody orders had to be enforced 7	Mother claimed the court erred by not enforcing interim orders.	Father argued the temporary-order issue was moot and unsupported.	Not reviewed; any challenge was moot and inadequately briefed. 8
Whether a material change in circumstances justified modification 9	Mother disputed that the evidence showed a material change.	Father argued ID's removal and escalating conflict showed changed circumstances.	Yes; the court found no abuse of discretion. 10
Whether modification was in the children's best interests 11	Mother argued the evidence and daughters' preferences favored her.	Father argued the statutory factors and GAL report favored him.	Yes; sufficient evidence supported placement with Father. 12

Adams v. Gallegos, 571 P.3d 337 (Wyo. 2025) (pro se litigants receive some leniency but must reasonably follow appellate rules 13)
In Int. of BFW, 395 P.3d 184 (Wyo. 2017) (issues without cogent argument or pertinent authority may be summarily affirmed 14)
McInerney v. Kramer, 537 P.3d 1146 (Wyo. 2023) (courts refuse to consider inadequately supported arguments 15)
Cornell v. Mecartney, 575 P.3d 349 (Wyo. 2025) (custody modification decisions are reviewed for abuse of discretion 16)
Brinda v. Walker, 562 P.3d 841 (Wyo. 2025) (best-interests analysis follows a material-change finding 17)
Kappen v. Kappen, 341 P.3d 377 (Wyo. 2015) (material change must affect the children's welfare 18)
Jackson v. Jackson, 96 P.3d 21 (Wyo. 2004) (trial courts must weigh family-specific best-interest factors and are better positioned to judge credibility 19)
Gardels v. Bowling, 522 P.3d 1047 (Wyo. 2023) (parental interference and controlling behavior can support changed circumstances and stability is crucial 20)
Gray v. Pavey, 158 P.3d 667 (Wyo. 2007) (appellate review views evidence favorably to the prevailing party and does not reweigh it 21)
Amadio v. Amadio, 564 P.3d 259 (Wyo. 2025) (appellate courts do not reweigh custody evidence 22)