## Facts

- Holly Lane Bruegman (Mother) and Colton Paul Bruegman (Father) married in 2008 and had one child (born 2014).
- After the child’s birth, the relationship deteriorated; Mother moved out and initiated divorce proceedings that were later dismissed without prejudice.
- Mother later filed a new divorce action; the district court entered a temporary order granting shared legal and physical custody and requiring Father to pay temporary child support.
- The district court dissolved the marriage by decree while reserving custody, visitation, support, and property issues for later trial.
- The child had developmental delays and received services through preschool programs; service providers in both parents’ communities were prepared to coordinate an individualized education program under a shared-custody arrangement.
- Mother offered videos of disputes between the parties; the courts found they did not show domestic violence or Father losing his temper with the child.
- After a bench trial, the district court ordered (1) shared legal and physical custody until kindergarten and (2) shared legal custody but primary physical custody to Father once the child entered kindergarten, with visitation to Mother.

## Issues

1. Whether the district court abused its discretion by awarding shared legal and physical custody before the child entered kindergarten.
2. Whether the district court abused its discretion by ordering a custody plan that shifted to Father as primary physical custodian when the child began kindergarten.
3. Whether prior Wyoming precedent disfavoring shared physical custody remained valid given the statutory best-interests framework.

## Decision

- The Wyoming Supreme Court affirmed the custody order in full.
- The court held the district court did not abuse its discretion in awarding shared physical custody for the pre-kindergarten period.
- The court held the district court did not abuse its discretion in providing that Father would become the primary physical custodian at kindergarten based on evidence presented at trial.
- The court overruled prior Wyoming precedent to the extent it imposed a general judicial disfavor of shared physical custody.

## Legal Principles

- Child custody determinations are governed by the child’s best interests under Wyoming’s statutory factors; appellate review is for abuse of discretion with deference to trial-level factfinding and credibility determinations.
- There is no statutory presumption for or against shared physical custody; shared custody must be evaluated on the facts under the best-interests factors.
- A custody order may include a stage-based structure tied to an anticipated developmental milestone (such as school entry) when the structure is supported by trial evidence and justified as serving the child’s best interests, rather than treated as a speculative future modification.

## Conclusion

The court affirmed a custody plan providing shared custody until kindergarten and primary physical custody to the father thereafter, and it rejected any categorical judicial disfavor of shared physical custody as inconsistent with Wyoming’s best-interests statute.


Bruegman v. Bruegman, 417 P.3d 157 (Wyo. 2018)