Martin v. Hart (Wyoming 2018)

A child support order must state the amount of presumptive support. If the court deviates from the presumptive amount, it must give specific reasons. The father filed to establish paternity, custody, and visitation of the child. In the final order, the court stated it was deviating from presumptive support without giving a presumptive amount. The deviation was for the cost of insurance and the father’s other child. The mother appealed. She argued that the court should not have deviated from presumptive support for either of the listed reasons. The Supreme Court reversed the child support order but for another ground. The Supreme Court found that the district court failed to specify the presumptive support amount and that it couldn’t figure out the presumptive support amount based on the evidence in the record. On remand, the Court encouraged the district court to receive and consider evidence to support any deviations.