Wyoming Statutes

Wyo. Stat. § 20-2-204 (2026)

Enforcement and modification.

✓ current as of May 2026

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(a) Either parent may petition to enforce or modify any
court order regarding custody and visitation.

     (b) A court having jurisdiction under W.S. 20-2-203 may,
upon appropriate motion of a party, require a parent to appear
before the court and show just cause why the parent should not
be held in contempt, upon a showing that the parent has
willfully violated an order concerning the care, custody and
visitation of the children. In order to enforce and require
future compliance with an order the court may find that the
parent is in contempt of court, award attorney's fees, costs and
any other relief as the court may deem necessary under the
circumstances to the party aggrieved by the violation of an
order.

     (c) A court having jurisdiction may modify an order
concerning the care, custody and visitation of the children if
there is a showing by either parent of a material change in
circumstances since the entry of the order in question and that
the modification would be in the best interests of the children
pursuant to W.S. 20-2-201(a). In any proceeding in which a
parent seeks to modify an order concerning child custody or
visitation, proof of repeated, unreasonable failure by the
custodial parent to allow visitation to the other parent in
violation of an order may be considered as evidence of a
material change of circumstances. Any modification under this
subsection shall be subject to the limitations and requirements
of W.S. 20-2-205.

Notes of Decisions

Cited in 67 cases (11 in the last 5 years), 2002–2025 · leading case: Amy Elise Evans f/k/a Amy Elise Sharpe v. Spencer Steven Sharpe, 2023 WY 55 (Wyo. 2023).

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Amy Elise Evans f/k/a Amy Elise Sharpe v. Spencer Steven Sharpe, 2023 WY 55 (Wyo. 2023). · cites it 10× “[¶20] Wyo. Stat. Ann. § 20-2-204 provides: Enforcement and modification.”

Womack v. Swan, 413 P.3d 127 (Wyo. 2018). · cites it 8× “However, as discussed above, Mother did not assert at the district court that the Temporary Order should have conclusive effect under the principles of res judicata and she cannot rely on the assertion now to impose retroactively the requirements of § 20-2-204(c).”

Jeffrey R. Arnott v. Paula a/k/a Polly A. Arnott, 2012 WY 167 (Wyo. 2012). · cites it 9× “[¶ 14] The applicability of res judica-ta has been functionally incorporated as a threshold inquiry under Wyo. Stat. Ann. § 20-2-204 (c) (LexisNexis 2009), enacted in 2000, which governs modification of child custody generally.”

Bishop v. Bishop, 404 P.3d 1170 (Wyo. 2017). · cites it 7× “[[Image here]] (c) A court having jurisdiction may modify an order concerning the care,.custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be…”

Jacobson v. Kidd, 426 P.3d 813 (Wyo. 2018). · cites it 7× “(c) A court having jurisdiction may modify an order concerning the care, custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be in the best…”

Meehan-Greer v. Greer, 415 P.3d 274 (Wyo. 2018). · cites it 6× “(c) A court having jurisdiction may modify an order concerning the care, custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be in the best…”

Johnson v. Clifford, 418 P.3d 819 (Wyo. 2018). · cites it 5× “§ 20-2-204 (LexisNexis 2017) contains the statutory requirements for the modification of custody and visitation orders: (a) Either parent may petition to enforce or modify any court order regarding custody and visitation. .... (c) A court having jurisdiction may modify an order…”

Kappen v. Kappen, 2015 WY 3 (Wyo. 2015). · cites it 8× “[¶13] The doctrine of res judicata “has been functionally incorporated as a threshold inquiry under Wyo. Stat. Ann. § 20-2-204 (c) (LexisNexis 20[13]).”

Hayzlett v. Hayzlett, 2007 WY 147 (Wyo. 2007). · cites it 6× “[T9] Pursuant to Wyo. Stat. Ann. § 20-2-204 (c), modification of child custody is a two-step process.”

Kimberly Shindell v. Roger Shindell, 2014 WY 51 (Wyo. 2014). · cites it 5× “20-2-203 may, upon appropriate motion of a party, require a parent to appear before the court and show just cause why the parent should not be held in contempt, upon a showing that the parent has willfully violated an order concerning the care, custody and visitation of the…”

Paden v. Paden, 403 P.3d 135 (Wyo. 2017). · cites it 4× “” Wyo. Stat. Ann. § 20-2-204 (e) (LexisNexis 2017).”

Kathryn Ann Heimer v. Mason William Heimer, 2021 WY 97 (Wyo. 2021). · cites it 4× “Wyo. Stat. Ann. § 20-2-204 (b) (LexisNexis 2019).”

Show all 67 citing cases →

— Wyo. Stat. § 20-2-204(a) — 1 case

Wild v. Adrian, 2007 WY 61 (Wyo. 2007).

— Wyo. Stat. § 20-2-204(b) — 5 cases

Kimberly Shindell v. Roger Shindell, 2014 WY 51 (Wyo. 2014). “20-2-203 may, upon appropriate motion of a party, require a parent to appear before the court and show just cause why the parent should not be held in contempt, upon a showing that the parent has willfully violated an order concerning the care, custody and visitation of the…”

William Waterbury v. Brenda Waterbury, N/K/A Brenda Frelsi, 2017 WY 11 (Wyo. 2017).

Womack v. Swan, 413 P.3d 127 (Wyo. 2018). “However, as discussed above, Mother did not assert at the district court that the Temporary Order should have conclusive effect under the principles of res judicata and she cannot rely on the assertion now to impose retroactively the requirements of § 20-2-204(c).”

Spencer Steven Sharpe v. Amy Elise Evans F/K/A Amy Elise Sharpe, 2025 WY 70 (Wyo. 2025).

William Waterbury v. Brenda Waterbury, N/K/A Brenda Frelsi, 2017 WY 11 (Wyo. 2017).

— Wyo. Stat. § 20-2-204(c) — 22 cases

Bishop v. Bishop, 404 P.3d 1170 (Wyo. 2017). “[[Image here]] (c) A court having jurisdiction may modify an order concerning the care,.custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be…”

Jacobson v. Kidd, 426 P.3d 813 (Wyo. 2018). “(c) A court having jurisdiction may modify an order concerning the care, custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be in the best…”

Meehan-Greer v. Greer, 415 P.3d 274 (Wyo. 2018). “(c) A court having jurisdiction may modify an order concerning the care, custody and visitation of the children if there is a showing by either parent of a material change in circumstances since the entry of the order in question and that the modification would be in the best…”

Johnson v. Clifford, 418 P.3d 819 (Wyo. 2018). “§ 20-2-204 (LexisNexis 2017) contains the statutory requirements for the modification of custody and visitation orders: (a) Either parent may petition to enforce or modify any court order regarding custody and visitation. .... (c) A court having jurisdiction may modify an order…”

Kappen v. Kappen, 2015 WY 3 (Wyo. 2015). “[¶13] The doctrine of res judicata “has been functionally incorporated as a threshold inquiry under Wyo. Stat. Ann. § 20-2-204 (c) (LexisNexis 20[13]).”

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