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Document Type

Case Notes

Subject Area

WY Law Division

Abstract

This case note first discusses the history of custody modification in Wyoming, followed by a discussion of the rules of statutory interpretation. Next, it provides a summary of the holding and analysis in Kappen. Finally, this case note argues that the court erred in Kappen, details how the statute should have been interpreted, and proposes an interpretation of the statute that is consistent with the legislature’s intent.

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