William Waterbury v. Brenda Waterbury, N/K/A Brenda Frelsi, 388 P.3d 532

Parties divorced in 2003; decree incorporated parents’ agreement requiring each parent to pay one-third of their daughters’ college costs (tuition, books, fees, room & board) while attending full-time before age 23.
In 2016, Brenda Waterbury moved to hold William Waterbury in contempt for failing to pay assigned college expenses for daughters Elizabeth and Sarah, alleging specific arrearages for tuition, room & board, books, and miscellaneous items.
The show-cause hearing was unreported; the district court found William in contempt and entered money judgments: $3,929.83 for Elizabeth, $331 for Sarah, and $5,136 in favor of Brenda for Sarah’s room and board.
William appealed, arguing (1) the district court lacked authority to enter judgments in favor of the adult daughters because they were not parties to the divorce action, and (2) there was insufficient evidence supporting the judgment awarded to Brenda.
The district court refused to approve William’s proposed statement of the evidence; no transcript was provided on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by entering judgment in favor of the adult daughters in the contempt proceeding	Waterbury (plaintiff) argued the daughters are third-party beneficiaries entitled to judgment	William argued the daughters were not parties to the divorce action and the court lacked authority to enter judgment for nonparties	Reversed: court cannot enter judgment for nonparties; daughters must bring their own enforcement action if appropriate
Whether the district court erred by entering judgment in favor of Brenda for arrearages (amount for Sarah’s room and board)	Brenda argued contempt proceeding and court’s calculations were supported by the evidence	William argued the court ‘‘made up’’ a formula and there was no evidentiary support; also failed to provide transcript or adequate statement on appeal	Affirmed: appellate court assumed record supported the district court because appellant failed to provide transcript or adequate statement of evidence

Roberts v. Locke, 304 P.3d 116 (Wyo. 2013) (standard of review for civil contempt in domestic relations cases)
Weiss v. Weiss, 217 P.3d 408 (Wyo. 2009) (children are not parties to a parents’ divorce action)
Olsen v. Olsen, 247 P.3d 77 (Wyo. 2011) (court cannot determine rights or award relief to nonparties)
Walker v. Walker, 311 P.3d 170 (Wyo. 2013) (district court may award money judgment to enforce divorce decree in contempt context)
Golden v. Guion, 299 P.3d 95 (Wyo. 2013) (appellant must provide transcript or adequate statement of evidence to challenge findings on appeal)