Johnson v. Johnson
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The Supreme Court affirmed in part and reversed in part the district court's decree of divorce and order awarding custody and dividing property and debts between Father and Mother, holding that the district court did not abuse its discretion in ordering supervised visitation and dividing the marital property but abused its discretion in calculating Father's child support amount.
Father argued that the district court abused its discretion in restricting Father's visitation with his four children to two hours of supervised visitation every other week until Father addressed the court's concerns regarding his anger. Father further argued that the court abused its discretion when it divided the marital property and when it found him voluntarily underemployed for not working overtime. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it imposed supervised visitation, finding Father had abused the children, and conditioning visitation on counseling for both Father and the children; (2) did not abuse its discretion in dividing the marital property; but (3) abused its discretion when it circumvented the express statutory limitation set forth in Wyo. Stat. Ann. 20-2-303(a)(ii) prohibiting courts from including in child support calculations any earnings derived from overtime work.
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