Tom D. Davidson v. Desiree A. Carrillo, 325 P.3d 444

Father challenged the district court’s Order on Child Custody and Order on Child Support following a trial over AD’s custody.
Father was awarded primary physical custody of AD; Mother received liberal visitation with set weekends and weekday evenings.
Trial occurred with Father pro se; both sides testified and no other witnesses were called.
The court ordered Mother to submit an updated financial affidavit; a later child support order set Mother’s support at $288.61 monthly, imputing income at minimum wage.
Father argued lack of notarized affidavit timing, retroactivity of support, and due process limits on cross-examination; the court’s rulings were challenged on visitation/child support and procedure.
Court affirmed, holding no abuse of discretion in custody/visitation, and rejecting due process and retroactivity challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was liberal visitation an abuse of discretion?	Father contends visitation favors Mother and creates de facto shared custody.	Mother argues best interests support liberal visitation; Father’s view of time is misapplied.	No abuse; visitation aligned with best interests and not a de facto shared arrangement.
Are findings of fact supported by the record?	Father argues the findings misstate evidence on parenting and fitness.	Mother asserts the findings reflect trial testimony and statutory factors.	Findings supported; Mother fit and both parents capable.
Did the court err by delaying support or not ordering support pendente lite?	Father asserts improper timing under § 20-2-308 and retroactivity.	Mother’s affidavits filed timely; retroactivity not required absent request or authority.	No error; no statutory timing violation or retroactive requirement.
Was Father denied due process or equal access to the court?	Father claims five minutes cross-exam insufficient and no rebuttal evidence allowed.	Mother argues hearing was meaningful; no offered proof of prejudice.	No due process violation; no prejudice shown from time limits.

Arnott v. Arnott, 2012 WY 167 (Wy. 2012) (custody decisions reviewed for abuse of discretion)
JKS v. AHF (In re ARF), 2013 WY 97 (Wy. 2013) (due process and meaningful hearing; cross-examination limits analyzed)
Aragon v. Aragon, 2005 WY 5 (Wy. 2005) (parental custody and sibling considerations; factors guiding best interests)
Dowdy v. Dowdy, 864 P.2d 439 (Wy. 1993) (keeping siblings together as a best-interest factor)
Testerman v. Testerman, 2008 WY 112 (Wy. 2008) (definition and use of 'parenting time' in Wyoming precedent)
Tafoya v. Tafoya, 2013 WY 121 (Wy. 2013) (visitation terminology and custody framework in Wyoming)
DH v. Wyo. Dep’t of Family Servs., 2003 WY 155 (Wy. 2003) (due process and meaningful hearing standards in Wyoming)
Durfee v. Durfee, 199 P.3d 1087 (Wy. 2009) (abuse of discretion and evidentiary review standards)