Wyoming's rule on child custody and parenting time turns on a feature the national template does not capture: Wyoming uses Legal custody and physical custody; visitation / parenting-time schedules implement physical custody.. Courts apply best-interests factors under § 20-2-201, including the child’s relationship with each parent, parental capacity, and any history of domestic violence. Joint custody may be ordered when in the child’s best interests; frequent contact with both parents is favored when safe. The controlling authority is Wyo. Stat. Ann. §§ 20-2-201 to 20-2-205. Relocation: A parent seeking to relocate with the child generally must show the move is in the child’s best interests; notice and modification practice follow the decree. Modification: A material change of circumstances is required to modify custody.
Key takeaways
- Best-interests standard: Courts apply best-interests factors under § 20-2-201, including the child’s relationship with each parent, parental capacity, and any history of domestic violence.
- Labels used in Wyoming: Legal custody and physical custody; visitation / parenting-time schedules implement physical custody..
- Parenting-time posture: Joint custody may be ordered when in the child’s best interests; frequent contact with both parents is favored when safe.
- Relocation: A parent seeking to relocate with the child generally must show the move is in the child’s best interests; notice and modification practice follow the decree.
- Modification: A material change of circumstances is required to modify custody.
- Primary authority: Wyo. Stat. Ann. §§ 20-2-201 to 20-2-205.
Worked example under Wyoming law
The illustration below uses only rules already stated for Wyoming. It is a research hypothetical, not a prediction of what a court will do.
Two parents in Wyoming disagree about where the child lives during the school week, and one wants to move.
- Use the labels Wyoming actually uses: Legal custody and physical custody; visitation / parenting-time schedules implement physical custody..
- Apply the best-interests factors: Courts apply best-interests factors under § 20-2-201, including the child’s relationship with each parent, parental capacity, and any history of domestic violence.
- Check any parenting presumption: Joint custody may be ordered when in the child’s best interests; frequent contact with both parents is favored when safe.
- If a move is proposed: A parent seeking to relocate with the child generally must show the move is in the child’s best interests; notice and modification practice follow the decree. Later changes follow: A material change of circumstances is required to modify custody.
Custody is addressed in divorce or a custody petition. Mediation may be ordered. Final decrees allocate legal and physical custody and a visitation schedule.
Best-interests factors in Wyoming
Courts apply best-interests factors under § 20-2-201, including the child’s relationship with each parent, parental capacity, and any history of domestic violence.
Legal custody, physical custody, and parenting time
Legal custody and physical custody; visitation / parenting-time schedules implement physical custody.
Joint custody may be ordered when in the child’s best interests; frequent contact with both parents is favored when safe.
Relocation with a child
A parent seeking to relocate with the child generally must show the move is in the child’s best interests; notice and modification practice follow the decree.
Modifying a Wyoming custody order
A material change of circumstances is required to modify custody.
How custody cases typically move in Wyoming
Custody is addressed in divorce or a custody petition. Mediation may be ordered. Final decrees allocate legal and physical custody and a visitation schedule.
Related Wyoming guides
Case law: custody and parenting time in Wyoming
Jeffrey R. ARNOTT, Appellant (Defendant), v. Paula A/K/A Polly A. ARNOTT, Appellee (Plaintiff)
…the parties' divorce decree, which granted primary physical custody of the parties' two daughters to Appellee, Paula ("Polly") Arnott (Mother). Father sought modification of custody after Mother gave notice of her intention to relocate to Virginia with the children. Relying on this Court's decision in Watt v. Watt, 971 P.2d 608, 614 (Wyo.1999), the district court applied a "str…
On child custody, Jeffrey R. ARNOTT, Appellant (Defendant), v. Paula A/K/A Polly A. ARNOTT, Appellee (Plaintiff) speaks to the Wyoming dispute in this passage: "Appellee, Paula ('Polly') Arnott (Mother). Father sought modification of custody after Mother gave notice of her intention to relocate to Virginia with the children. Relying on this Court's decision in Watt v. Watt, 971 P.2d 608, 614 (Wyo." The surrounding opinion shows how the court applied that language to the record.
Willard Donald BISHOP, (Plaintiff) v. Jorja Anna BISHOP, n/k/a Jorja Anna Manolis, (Defendant)
…difying the divorce decree by transferring primary physical custody of the parties’ son (the Child) to Jorja Anna Bishop, n/k/a Jorja Anna Manolis (Mother). Father claims the district court abused its discretion when it concluded (a) that Mother had proven a material change in circumstances affecting the Child had occurred since entry of the divorce decree, and (b) that it was…
Wyoming opinions such as Willard Donald BISHOP, (Plaintiff) v. Jorja Anna BISHOP, n/k/a Jorja Anna Manolis, (Defendant) are cited where child custody is disputed. The court stated: "Child) to Jorja Anna Bishop, n/k/a Jorja Anna Manolis (Mother)." That is the language to brief; the rest of the decision supplies the procedural posture.
Misty Schanell JACKSON, Appellant (Plaintiff/Respondent), v. Kevin Wayne JACKSON, Appellee (Defendant/Petitioner)
…ances, Kevin Jackson filed a petition for modification of a custody order which granted his former wife, Misty Jackson, primary physical custody of their two children. The district court granted the petition and awarded Mr. Jackson primary physical custody of the children because he had substantially improved his life and had become more stable, whereas Ms. Jackson had not. Ms.…
Wyoming opinions such as Misty Schanell JACKSON, Appellant (Plaintiff/Respondent), v. Kevin Wayne JACKSON, Appellee (Defendant/Petitioner) are cited where child custody is disputed. The court stated: "Kevin Jackson filed a petition for modification of a custody order which granted his former wife, Misty Jackson, primary physical custody of their two children. The district court granted the petition and awarded Mr." That is the language to brief; the rest of the decision supplies the procedural posture.
Kari Jo ROEMMICH, Appellant (Defendant), v. Shane Christopher ROEMMICH, Appellee (Plaintiff)
KITE, Chief Justice. [T1] When shared physical custody of their child failed, Kari Jo Roemmich (Mother) filed a petition for custody modification seeking primary physical custody of the child with reasonable visitation for Shane Christopher Roemmich (Father). After a hearing on the petition, the district court awarded Father primary physical custody with reasonable…
Kari Jo ROEMMICH, Appellant (Defendant), v. Shane Christopher ROEMMICH, Appellee (Plaintiff) is worth reading on Wyoming child custody because the court put the point in its own words: "KITE, Chief Justice. [T1] When shared physical custody of their child failed, Kari Jo Roemmich (Mother) filed a petition for custody modification seeking primary physical custody of the child with reasonable visitation for Shane Christopher Roemmich (Father)." Use that passage as the starting point, then read the facts that precede it.
Justin Dean EICKBUSH, Appellant (Plaintiff), v. Lisa Ann EICKBUSH, Appellee (Defendant)
…district court that the parties had reached an agreement on custody and that the parties would exercise shared custody, alternating weekly. When the parties later were unable to agree on the terms of custody, Mother filed a motion to enforce the settlement agreement. At a hearing, Mother insisted that their agreement should be enforced; however, Father contended that shared cus…
Justin Dean EICKBUSH, Appellant (Plaintiff), v. Lisa Ann EICKBUSH, Appellee (Defendant) is worth reading on Wyoming child custody because the court put the point in its own words: "When the parties later were unable to agree on the terms of custody, Mother filed a motion to enforce the settlement agreement." Use that passage as the starting point, then read the facts that precede it.
Melissa L. GRAY, Appellant (Respondent), v. John W. PAVEY, A/K/A JOHNNY W. Pavey, Appellee (Petitioner)
…lissa Gray ("Mother") appeals from an order modifying child custody. She contends that the change in custody is contrary to her daughter's best interests. We affirm. ISSUE [¶ 2] The issue for review is whether the district court abused its discretion by awarding custody of the parties' minor child ("C.G.") to her father, John Pavey ("Father"). FACTS [¶ 3] Mother and Father are…
Practitioners open Melissa L. GRAY, Appellant (Respondent), v. John W. PAVEY, A/K/A JOHNNY W. Pavey, Appellee (Petitioner) when Wyoming child custody turns on the distinction in this sentence: "Gray ('Mother') appeals from an order modifying child custody. She contends that the change in custody is contrary to her daughter's best interests. We affirm." Do not lift it out of the facts the court was deciding.
DJG, Appellant (Defendant), v. MAP, Appellee (Plaintiff)
DJG, Appellant (Defendant), v. MAP, Appellee (Plaintiff), 1994 Wyo. LEXIS 131 (1994)
…n original decree between the parties with respect to child custody provisions, claiming that the trial court erred in determining that a change in circumstances sufficient to allow modification of the original child custody decree had occurred and that the best interests of the child favored a change in custody. We affirm. The mother sets out two issues for our consideration:…
DJG, Appellant (Defendant), v. MAP, Appellee (Plaintiff) is worth reading on Wyoming child custody because the court put the point in its own words: "n original decree between the parties with respect to child custody provisions, claiming that the trial court erred in determining that a change in circumstances sufficient to allow modification of the original child custody decree had occurred and that the best interests of the" Use that passage as the starting point, then read the facts that precede it.
In the Matter of the ADOPTION OF BBC. BDR, Appellant (Respondent), v. BEB and PJB, Appellees (Petitioners)
…rom a judgment and final decree of adoption denying him the custody of his child, terminating his parental rights, and declaring the child adopted by Appellees BEB and PJB, the adoptive parents. We reverse the order terminating the father's parental rights and the order decreeing the adoption of the child, affirm the order denying custody of BBC to the father, and remand for fu…
Practitioners open In the Matter of the ADOPTION OF BBC. BDR, Appellant (Respondent), v. BEB and PJB, Appellees (Petitioners) when Wyoming child custody turns on the distinction in this sentence: "Appellees BEB and PJB, the adoptive parents." Do not lift it out of the facts the court was deciding.
Frequently asked questions
What does Wyoming call “custody”?
Legal custody and physical custody; visitation / parenting-time schedules implement physical custody.
Can I move out of state with my child?
A parent seeking to relocate with the child generally must show the move is in the child’s best interests; notice and modification practice follow the decree.
How do I change an existing custody order in Wyoming?
A material change of circumstances is required to modify custody.
This guide covers Wyoming custody law as of 2026. Verify the live statute and any local parenting-time guidelines before relying on this summary.