## Facts

- Clayton Eugene Long (Husband) and Satin Marie Long (Wife) married in 1993 and had four children.
- After marital conflict and Wife’s stated intent to divorce, Husband texted Wife that if she wanted a divorce she should have an attorney prepare paperwork reflecting the terms she wanted.
- Wife’s counsel prepared a stipulated judgment and decree addressing property division, primary custody to Wife, approximately $3,000/month in alimony, and approximately $3,000/month in child support.
- Husband, who had moderate dyslexia, signed the stipulated decree before a notary without written changes after Wife explained the terms and told him he could cross out provisions he opposed.
- Wife filed for divorce and submitted the stipulated decree; after an evidentiary hearing, the district court adopted it as the divorce decree with a minor reduction in child support.
- The district court found the stipulation enforceable, supported by consideration, not unconscionable, and not the product of duress, coercion, bad faith, or incompetence.
- Husband appealed, challenging enforceability and arguing the decree lacked required findings concerning custody, child support, and alimony.

## Issues

1. Whether the stipulated divorce agreement was enforceable as a contract, including whether it was supported by consideration and whether it was unconscionable.
2. Whether Husband proved he signed the agreement while incompetent or under duress, coercion, or bad faith.
3. Whether the custody award was an abuse of discretion due to insufficient best-interest analysis.
4. Whether the child support order required remand for failure to make statutorily required guideline findings.
5. Whether the alimony award required additional findings or constituted an abuse of discretion.

## Decision

- The Wyoming Supreme Court affirmed the district court’s enforcement of the stipulated decree as a valid settlement agreement incorporated into the divorce judgment.
- The Court upheld findings that the agreement was supported by consideration and was not unconscionable.
- The Court affirmed the rejection of Husband’s claims of duress, coercion, bad faith, and incompetence.
- The Court affirmed the custody and alimony provisions despite limited express findings, concluding the record supported the district court’s exercise of discretion.
- The Court remanded in part for the limited purpose of entering statutorily adequate findings regarding child support.

## Legal Principles

- A stipulated divorce decree is treated as a contractual settlement; it is generally enforceable if entered voluntarily and not contrary to law or public policy.
- Consideration may be satisfied by mutual promises to settle disputed divorce issues and avoid contested litigation; economic inequality alone does not negate consideration.
- Unconscionability requires more than a lopsided bargain; courts consider both procedural fairness (opportunity to understand and reject terms) and substantive extremity.
- Claims of duress, coercion, bad faith, or incompetence require evidence of wrongful pressure or incapacity; emotional distress or learning difficulties do not alone establish legal incompetence.
- Custody determinations must reflect the children’s best interests; detailed factor-by-factor findings are not always required if the record shows the standard was applied.
- Child support orders must comply with statutory guideline procedures and required findings; stipulation and available income information do not eliminate the court’s duty to enter compliant findings.
- Alimony awards are reviewed for abuse of discretion, and courts may rely on the parties’ stipulation and record evidence of need and ability to pay.

## Conclusion

The court enforced the parties’ stipulated divorce settlement as a valid contract and affirmed the resulting property, custody, and alimony provisions, but remanded for the district court to enter required statutory findings supporting the child support order.


Long v. Long, 413 P.3d 117 (Wyo. 2018)