A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more. Separately, a substantial change of circumstances supports modification at any time, and every three years either parent may request review and adjustment without showing changed circumstances. That is what separates Wyoming modifying child support from a generic national summary. Read Wyo. Stat. §§ 20-2-311, 20-6-304 before the background sections below. File a petition for review and adjustment filed in district court, or a DFS administrative review. Adjustments run prospectively from the petition; arrears are not retroactively forgiven. DFS conducts three-year reviews of IV-D orders without a changed-circumstances showing.
What counts as a change in Wyoming
Facts that most often support modification:
- Income changes. Job loss, demotion, retirement, disability, or a significant raise on either side. Voluntary quits and deliberate underemployment usually backfire — courts may impute income.
- Parenting-time shifts. A new custody order, a child moving households, or substantial unexercised visitation.
- The child's needs. New medical or educational expenses, health-insurance changes, or a child reaching an age that changes the guideline bracket.
- Guideline updates. In many states, a recalculated guideline amount that differs from the current order by the statutory margin is itself the change — Wyo. Stat. §§ 20-2-311, 20-6-304 controls how that math works here.
- Incarceration, military deployment, or other statutory events that Wyoming treats as qualifying changes.
Facts that rarely work: a short gap between jobs, a new partner's income (usually not imputed to a parent), lifestyle choices, or the passage of time alone where Wyoming still requires a showing.
Step-by-step: how to file
A petition for review and adjustment filed in district court, or a DFS administrative review. The typical sequence:
- Confirm jurisdiction. Wyoming courts modify their own orders; if the child and parties have moved, the Uniform Interstate Family Support Act (UIFSA) determines which state may act. Generally the issuing state keeps exclusive continuing jurisdiction until all parties and the child have left, or the parties agree in writing to transfer.
- Gather financial proof. Two to three years of tax returns, recent pay stubs, proof of benefits or disability, health-insurance costs, and child-care invoices. Expect a financial affidavit or worksheet under Wyo. Stat. §§ 20-2-311, 20-6-304.
- File the modification request. A petition for review and adjustment filed in district court, or a DFS administrative review.
- Serve the other parent. Service starts the retroactivity clock in most states — delays cost you.
- Exchange discovery. Interrogatories, document requests, and sometimes a vocational evaluation if underemployment is disputed.
- Negotiate or litigate. Many modification cases settle at mediation or a case-management conference; a stipulated modification must still be approved and entered by the court.
- Get the new order entered. Support does not change until a judge signs — keep paying the existing order until then.
When the change takes effect (retroactivity)
Adjustments run prospectively from the petition; arrears are not retroactively forgiven.
This is the single most expensive mistake in modification practice. If circumstances changed in January but the motion is filed in June, the months in between are almost always governed by the old order. Filing promptly — even before you have perfect evidence — protects the effective date.
A concrete Wyoming scenario
Here is one way the Wyoming pieces fit together. Change any fact and the statute may point somewhere else.
A parent in Wyoming lost income after the last child-support order and wants the number changed.
- File in the district court that entered the order, or the Department of Family Services (DFS) Child Support Program using a petition for review and adjustment filed in district court, or a DFS administrative review.
- Prove the Wyoming standard: A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more. Separately, a substantial change of circumstances supports modification at any time, and every three years either parent may request review and adjustment without showing changed circumstances.
- Expect the effective date to follow this rule: Adjustments run prospectively from the petition; arrears are not retroactively forgiven.
- If the case is IV-D, also consider administrative review: DFS conducts three-year reviews of IV-D orders without a changed-circumstances showing.
A Wyoming modification is a new order under Wyo. Stat. §§ 20-2-311, 20-6-304. It is not automatic, and arrears already due generally stay due.
Periodic reviews and administrative modification
DFS conducts three-year reviews of IV-D orders without a changed-circumstances showing.
Administrative review is often faster and cheaper than litigation, but its scope is narrower: agencies adjust amounts under the guidelines, while only the district court that entered the order, or the Department of Family Services (DFS) Child Support Program can resolve disputed facts about custody, income imputation, or deviations.
Interstate cases (UIFSA)
When parents live in different states, a Wyoming order can usually be registered and enforced anywhere, but modification follows UIFSA's jurisdictional rules. Register the order in the responding state, then seek modification where the law permits it. Do not simply stop paying while a jurisdictional fight is pending — arrears keep accruing under the existing order.
Case law: how Wyoming courts decide modification motions
The opinions below are in the LawDiver corpus, with block quotes pulled from the opinion text so you can jump straight into the full decisions.
Norman R. MANNERS, Appellant (Defendant), v. Sharlet Gay MANNERS, Appellee (Plaintiff)
…trial court executed an order based on appellee’s petition modifying the child support provision of the decree of divorce. Appellant raises the following issues: “The trial court erred in finding that the child support ordered in the original decree of divorce was unreasonably low. “The trial court erred in finding that there had been a change in circumstances warranting modif…
Practitioners open Norman R. MANNERS, Appellant (Defendant), v. Sharlet Gay MANNERS, Appellee (Plaintiff) when Wyoming child support modification turns on the distinction in this sentence: "Appellant raises the following issues: “The trial court erred in finding that the child support ordered in the original decree of divorce was unreasonably low." Do not lift it out of the facts the court was deciding.
Eugene Dale SWANEY, Appellant (Respondent), v. the STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT
…details of child support amounts, payments, arrearages, and modifications are not relevant to resolution of the dispute. Mother obtained custody of the parties' children and Father was ordered to pay child support. Father's efforts in that regard were less than stellar, and child support arrearages developed. Due to a disability arising after the initial court order, Father's c…
Eugene Dale SWANEY, Appellant (Respondent), v. the STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT is worth reading on Wyoming child support modification because the court put the point in its own words: "Mother obtained custody of the parties' children and Father was ordered to pay child support. Father's efforts in that regard were less than stellar, and child support arrearages developed." Use that passage as the starting point, then read the facts that precede it.
Clint Raymond Webb v. State of Wyoming, Ex Rel. Department of Family Services, Child Support Enforcement Division
…vorce decree.1 Several years later, Clint filed a motion to modify and correct the child support order, arguing it was unconstitutional because it conflicted with federal law. The district court denied the motion. Finding no abuse of discretion, we affirm. ISSUE [¶2] The dispositive issue is: Did the district court abuse its discretion in denying Clint’s “Motion to Modify and C…
Wyoming opinions such as Clint Raymond Webb v. State of Wyoming, Ex Rel. Department of Family Services, Child Support Enforcement Division are cited where child support modification is disputed. The court stated: "Several years later, Clint filed a motion to modify and correct the child support order, arguing it was unconstitutional because it conflicted with federal law. The district court denied the motion. Finding no abuse of discretion, we affirm." That is the language to brief; the rest of the decision supplies the procedural posture.
The STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, Child Support Enforcement, Appellant (Intervenor), v. Connie M
…We hold that the district court was without jurisdiction to modify the 2008 child support order and remand for entry of an order consistent with our direction herein. *859 ISSUE [12] The Department presents the following issue on appeal: In 2012, the district court ordered a retroactive recaleulation of child support against Connie Powell, the non-custodial mother. The district…
On child support modification, The STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, Child Support Enforcement, Appellant (Intervenor), v. Connie M speaks to the Wyoming dispute in this passage: "We hold that the district court was without jurisdiction to modify the 2008 child support order and remand for entry of an order consistent with our direction herein." The surrounding opinion shows how the court applied that language to the record.
TSR, f/k/a TSH, (Respondent) v. STATE of Wyoming, EX REL., DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT ENFORCEMENT
…¶1] Appellant, TSR, appeals from the district court’s order modifying child support with respect to her daughter, LLB. She claims the court abused its discretion in determining child support. We affirm. ISSUES [¶2] Appellant presents the following issues: 1. Whether the District Court abused its discretion by using the matrix for two (2) children rather than one (1) child in W.…
On child support modification, TSR, f/k/a TSH, (Respondent) v. STATE of Wyoming, EX REL., DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT ENFORCEMENT speaks to the Wyoming dispute in this passage: "Appellant, TSR, appeals from the district court’s order modifying child support with respect to her daughter, LLB. She claims the court abused its discretion in determining child support. We affirm. ISSUES [¶2] Appellant presents the following issues: 1." The surrounding opinion shows how the court applied that language to the record.
Michael Scott Carroll, II v. State of Wyoming, ex rel. Department of Family Services, Child Support Enforcement
…nt Division (“Department”) petitioned the district court to modify Michael Scott Carroll, II’s 2012 child support order. Mr. Carroll answered and requested the court relieve him of his child support arrears. He claimed the statutory minimum child support obligation of $50 was unconstitutional. The district court denied his request for relief, modified the child support order, a…
Practitioners open Michael Scott Carroll, II v. State of Wyoming, ex rel. Department of Family Services, Child Support Enforcement when Wyoming child support modification turns on the distinction in this sentence: "Division (“Department”) petitioned the district court to modify Michael Scott Carroll, II’s 2012 child support order. Mr. Carroll answered and requested the court relieve him of his child support arrears." Do not lift it out of the facts the court was deciding.
Timothy S. O'Roake v. State of Wyoming, ex rel. Department of Family Services, Child Support Enforcement Division
…pport Enforcement Division (DFS) successfully petitioned to modify child support. [¶4] At issue is DFS’s second motion to modify support filed in May 2020. A court commissioner held an unreported hearing on the motion. 3 The district court adopted the 1 Father also contends that the district court violated his right to due process by ordering post-majority support after ZAO gra…
Practitioners open Timothy S. O'Roake v. State of Wyoming, ex rel. Department of Family Services, Child Support Enforcement Division when Wyoming child support modification turns on the distinction in this sentence: "Enforcement Division (DFS) successfully petitioned to modify child support. [¶4] At issue is DFS’s second motion to modify support filed in May 2020. A court commissioner held an unreported hearing on the motion." Do not lift it out of the facts the court was deciding.
Steve John GRENZ, Appellant, Respondent, v. the STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT
…ellant, Steve John Grenz, challenges a district court order modifying his child support payments. He contends the district court failed to provide him proper credit against his child support obligations for court-ordered abatements he had received. We find no error and affirm. ISSUE [¶ 2] Mr. Grenz presents a single issue: Did the district court err when it failed to follow and…
On child support modification, Steve John GRENZ, Appellant, Respondent, v. the STATE of Wyoming, DEPARTMENT OF FAMILY SERVICES, CHILD SUPPORT speaks to the Wyoming dispute in this passage: "Steve John Grenz, challenges a district court order modifying his child support payments. He contends the district court failed to provide him proper credit against his child support obligations for court-ordered abatements he had received. We find no error and affirm." The surrounding opinion shows how the court applied that language to the record.
Practical checklist before you file
- Re-read the existing order: does it recite a modification standard, a reservation of jurisdiction, or agreed deviation findings? Those terms shape your burden.
- Run the current Wyoming guideline calculation on today's incomes before filing; know the percentage gap.
- Assemble documents that date the change (termination letter, disability award, new lease, custody order).
- Calendar the three-year review cycle if Wyoming offers one for your case type.
- Keep paying the current order until a new one is entered — arrears are nearly impossible to erase later.
- Search LawDiver for recent Wyoming modification decisions before briefing or mediating.
Key takeaways
- Wyoming modification actions are filed in the district court that entered the order, or the Department of Family Services (DFS) Child Support Program.
- The legal standard: A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more.
- Adjustments run prospectively from the petition; arrears are not retroactively forgiven.
- DFS conducts three-year reviews of IV-D orders without a changed-circumstances showing.
- A modification is never automatic — even when a percentage threshold is met, the court must enter a new order.
- Companion reading: Wyoming child support guidelines and how to modify alimony in Wyoming.
The legal standard in Wyoming
A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more. Separately, a substantial change of circumstances supports modification at any time, and every three years either parent may request review and adjustment without showing changed circumstances.
In practice, the moving parent carries the burden. The court compares the facts as they stood when the last order was entered against the facts today, and asks whether the difference is significant enough — and durable enough — to justify a new order. Judges distinguish between temporary setbacks (a few weeks of reduced hours) and genuine, continuing changes (a layoff, a new custody schedule, a child's changed medical needs).
Frequently asked questions
Can child support be modified in Wyoming?
Yes. A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more. Separately, a substantial change of circumstances supports modification at any time, and every three years either parent may request review and adjustment without showing changed circumstances. Modifications are handled through a petition for review and adjustment filed in district court, or a DFS administrative review.
How much does income have to change to modify child support in Wyoming?
A petition for review and adjustment is available for any order entered more than six months ago that has not been adjusted within the prior six months, where applying the presumptive guidelines would change the monthly amount by 20% or more. Separately, a substantial change of circumstances supports modification at any time, and every three years either parent may request review and adjustment without showing changed circumstances. Some changes — custody shifts, medical needs, or statutory events — qualify even without hitting a numeric threshold.
Can Wyoming child support be modified retroactively?
Adjustments run prospectively from the petition; arrears are not retroactively forgiven. Plan on the current order controlling until a new one is entered.
Who can request a modification?
Either parent, and in IV-D cases the state child support agency on a parent's behalf. DFS conducts three-year reviews of IV-D orders without a changed-circumstances showing.
Do I need a lawyer to modify child support in Wyoming?
Not always — the district court that entered the order, or the Department of Family Services (DFS) Child Support Program accepts filings from self-represented parents, and administrative reviews are designed for that. Contested income imputation, self-employment income, or interstate jurisdiction issues are where counsel matters most.
Does the other parent's refusal to follow the visitation order change support?
Not automatically. Custody interference and support are legally distinct issues in Wyoming; withholding support in response to withheld visitation typically creates arrears and contempt exposure. Seek modification or enforcement of the parenting order through the court instead.
Related guides
- How Wyoming calculates child support
- Wyoming alimony / alimony guide
- How to modify alimony in Wyoming
- How to modify child support in Wyoming
Disclaimer
This guide is general legal information about modifying child support in Wyoming, not legal advice. Statutes, guidelines, and case law change. Confirm the current text of Wyo. Stat. §§ 20-2-311, 20-6-304 and consult a licensed Wyoming family-law attorney about your specific order.