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December 2, 2005
Case Law Development: "Unconventional Custody" Arrangements Requires Express Findings
The Wyoming Supreme Court reversed a trial court's default divorce judgment, which among other things had split custody of the two children between the parents. The Court noted that the trial court failed to make any findings to support its property distribution and its custody determination. In particular, the court emphasized that "when the exercise of its discretion in custody matters involves splitting custody of children between parents or other unconventional custody approaches, the trial court must provide an explanation of its reasoning and place its findings on the record."
Noonan v. Anderson, 2005 WY 145, 2005 Wyo. LEXIS 175 (November 22, 2005)
Opinion on the web at http://courts.state.wy.us/2005opn/2005WY145.pdf (last visited November 30, 2005 bgf)