Margaret Lucille Largent, n/k/a Margaret L. Wolfe v. John D. Largent

Summary

The Wyoming Supreme Court reviewed the setting aside of a default judgment and the denial of confirmation and enforcement of a Washington child support order registered in Wyoming. The court affirmed relief from the default judgment under W.R.C.P. 60(b), but held that partial payment and related defenses did not justify denying enforcement of the foreign support order in its entirety. It reversed and remanded for calculation of the proper arrearages and interest and for entry of an appropriate enforcement order.

Holdings

1. The district court had jurisdiction to consider Largent's motion to set aside the default judgment under W.R.C.P. 55(c) and 60(b), even though the registered order had been confirmed by operation of law after the twenty-day contest period expired.
2. The district court did not abuse its discretion by setting aside the default judgment based on excusable neglect.
3. Partial payment is not a complete defense to confirmation and enforcement of a valid foreign child-support order. The district court erred by denying confirmation and enforcement of the Washington decree in its entirety.

Questions Presented

1. Whether the Wyoming district court had jurisdiction to consider Largent's motion under W.R.C.P. 55(c) and 60(b) despite the statutory period for contesting registration of the foreign child-support order.
2. Whether the district court abused its discretion by granting relief from the default judgment under W.R.C.P. 60(b)(1) based on mistake, inadvertence, surprise, or excusable neglect.
3. Whether the district court abused its discretion by denying confirmation and enforcement of the Washington child-support order in its entirety when Largent established only partial-payment and other potential defenses affecting the amount owed.

Disposition

reversed_and_remanded