Martin v. Martin

In Martin v. Martin, 798 P.2d 321 (Wyo. 1990), the trial court provided in a divorce decree for an automatic custody modification if either party moved from Laramie, Wyoming. The supreme court held the trial court abused its discretion, explaining that speculation about the effects of a possible future move "is not a substitute for complete analysis of all existing circumstances when and if a change in the established child custody arrangement becomes necessary." Id. at 323.