The State of Wyoming, Department of Family Services, Child Support Enforcement v. Connie M. Powell, 300 P.3d 858

In 1999, Father obtained custody of both children; Mother had no child support obligation per the modified decree.
August 4, 2003, the district court issued an order addressing medical, travel, and child support arrears, setting retroactive support to 1999.
No party filed financial affidavits or requested a hearing on child support as ordered in 1999/2003, and the case lay dormant until 2003–2004 motions arose.
March 2004 hearing occurred without a written order; it is unclear what was decided or whether the 2003 order was modified or vacated.
In 2009 the Department sought contempt and information; in 2010-2012, the court attempted to address March 2004 proceedings but without clear records.
June 29, 2012, the district court set aside the August 4, 2003 order and recalculated child support retroactively to the date Father obtained custody, prompting the Department’s appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court have authority to modify the 2003 order retroactively?	Department argues modification within statutory power or pending petition.	Powell contends court lacked jurisdiction absent a petition or proper motion.	No jurisdiction to modify; retroactive modification not authorized.

Weiss v. Weiss, 217 P.3d 408 (Wyo. 2009) (district court lacked jurisdiction to modify without petition)
Parry v. Parry, 766 P.2d 1168 (Wyo. 1989) (retrospective modification disfavored; discourages self-help)
Thomas v. Thomas, 983 P.2d 717 (Wyo. 1999) (no retroactive modification beyond petition date absent agreement)
Connors v. Connors, 769 P.2d 336 (Wyo. 1989) (petition to modify required for court’s jurisdiction)
Bush v. State, 79 P.3d 1178 (Wyo. 2003) (divorce modification authority limited to statute)
Urbach v. Urbach, 73 P.2d 953 (Wyo. 1937) (divorce process and statutory limits on court power)