Wyoming courts do not automatically include extracurricular activities in basic child support calculations. Under Wyo. Stat. § 20-2-304, the presumptive child support amount covers housing, food, clothing, school supplies, and reasonable recreation—but costly extracurricular programs like travel sports, private music lessons, and competitive activities require separate negotiation or court allocation. Parents typically share these expenses proportionally based on income, with the higher-earning parent often covering 60-70% of activity costs. Filing fees in Wyoming range from $85 to $160 depending on county, and the state requires only 60 days of residency before filing—the shortest requirement in the nation.
Key Facts: Extracurricular Activities and Child Support in Wyoming
| Category | Wyoming Rule |
|---|---|
| Filing Fee | $85–$160 (varies by county) |
| Residency Requirement | 60 days minimum |
| Waiting Period | None after filing |
| Grounds for Divorce | No-fault (irreconcilable differences) |
| Property Division | Equitable distribution |
| Child Support Model | Income shares model |
| Modification Threshold | 20% change in support amount |
| Extracurriculars in Basic Support | Not automatically included |
| Deviation Authority | Wyo. Stat. § 20-2-307 |
What Counts as Extracurricular Activities Under Wyoming Law
Wyoming courts define extracurricular activities as voluntary programs that fall outside basic educational and living expenses covered by standard child support. Under Wyo. Stat. § 20-2-304, basic child support covers housing, food, clothing, school supplies, personal care items, transportation, and reasonable recreational activities—but does not automatically include costly extracurricular programs. Courts distinguish between reasonable recreation (neighborhood sports leagues costing $50-100 per season) and extraordinary extracurricular expenses (travel teams costing $2,000-10,000 annually).
Extracurricular activities requiring separate allocation include:
- Organized sports leagues and travel team fees ($500-$8,000 per year)
- Private music, dance, or art lessons ($100-$300 per month)
- Academic tutoring and test preparation ($50-$150 per hour)
- Summer camps and specialty programs ($500-$5,000 per session)
- Competitive activities requiring equipment, travel, and tournament fees
- Club memberships and organization dues
- Special clothing, uniforms, and equipment for activities
In the Wyoming Supreme Court case Cranston v. Cranston, 879 P.2d 345 (1994), the court examined extracurricular expenses including swimming and karate lessons. The mother testified she paid for all extracurricular activities of the children, and the father refused to share in those expenses. The court held that both parents must contribute to the expenses of the children in a substantial manner when seeking shared custody benefits.
How Wyoming Courts Allocate Extracurricular Costs Between Parents
Wyoming uses the income shares model for child support under Wyo. Stat. § 20-2-304, which calculates each parent's proportional contribution based on their percentage of combined parental income. Courts typically apply this same proportional approach when allocating extracurricular activity costs separately from basic support. If one parent earns $80,000 annually and the other earns $40,000, the higher-earning parent would pay approximately 67% of agreed-upon extracurricular expenses while the lower-earning parent pays 33%.
Courts consider these factors when allocating extracurricular costs:
- Each parent's gross monthly income and percentage of combined income
- The child's established pattern of participation in activities before divorce
- Whether the activity was mutually agreed upon by both parents
- The reasonableness of the activity cost relative to family income
- Transportation logistics and which parent transports the child to activities
- The child's age and demonstrated commitment to the activity
Under Wyo. Stat. § 20-2-307, courts may deviate from presumptive child support when the standard calculation would be unjust or inappropriate. Courts have used this deviation authority to include regular extracurricular costs in modified support orders when both parents agree the activities benefit the child's development.
The Christensen Deviation for Extraordinary Child Expenses
Wyoming courts, particularly in Sweetwater County, recognize the Christensen Deviation as a mechanism to adjust child support based on payment of expenses above what basic support covers. This deviation can result in a change in child support obligation of more than 50% when a parent regularly pays for significant additional expenses including extracurricular activities, sporting equipment, school lunches, and other extraordinary costs.
Expenses that may qualify for a Christensen Deviation include:
- Health insurance premiums paid for children
- School clothes purchased beyond basic needs
- Cash given directly to children for activities
- Sporting equipment and uniform costs ($200-$2,000 per activity)
- School lunches and meal program fees
- Costs associated with vehicles provided for teenage children (insurance, payments, gas, maintenance)
- Tutoring and academic enrichment programs
- Musical instruments and lesson fees
To request a Christensen Deviation, parents must document all additional expenses paid over the basic support amount with receipts, bank statements, and detailed records. Courts require specific findings on the record explaining why the deviation serves the child's best interests and how the adjusted amount was calculated under Wyo. Stat. § 20-2-307(b).
How to Include Extracurricular Costs in Your Divorce Decree
Parents should address extracurricular activity costs explicitly in their divorce decree or parenting plan rather than leaving them to future disputes. Wyoming courts encourage detailed written agreements that specify how activity decisions are made, how costs are divided, and what approval process applies to new activities. Approximately 80% of extracurricular cost disputes arise from vague or missing provisions in the original divorce decree.
Your divorce decree should include:
- A list of currently approved activities and the cost-sharing percentage for each
- A cap on annual extracurricular spending (e.g., $3,000 per child per year)
- A requirement for written consent before enrolling in new activities above a threshold amount (e.g., $500)
- Specification of who pays registration fees upfront and how reimbursement works
- A deadline for reimbursement requests (e.g., within 30 days of providing receipt)
- Transportation responsibilities for practices and events
- A dispute resolution process if parents disagree about an activity
Courts look favorably on agreements where both parents must approve activities costing more than $250-500 per season. This prevents one parent from unilaterally enrolling children in expensive programs and demanding the other parent pay their share.
Modifying Child Support to Include Extracurricular Expenses
Wyoming allows child support modification when circumstances change substantially enough to alter the support calculation by at least 20% under Wyo. Stat. § 20-2-311. Rising extracurricular costs alone rarely meet this threshold, but combined with income changes or other factors, parents can petition for modification to formally include activity expenses in the support order.
Grounds for modification related to extracurricular activities include:
- A 20% or greater change in either parent's income affecting ability to pay
- A child beginning competitive activities with costs exceeding $3,000 annually
- Substantial increases in existing activity costs (e.g., local league to travel team)
- Changes in custody time affecting which parent pays direct activity costs
- One parent's failure to pay their agreed share of activity expenses
The Wyoming Child Support Program offers free modification assistance by calling (307) 777-5300. The program will gather income information from both parents and calculate whether the current order differs from guideline amounts by at least 20%. If so, the program can petition the court for modification at no cost to either parent.
Every three years, either parent may request a review and adjustment of child support under Wyo. Stat. § 20-2-311 without showing a change in circumstances. Parents can use this three-year review to formally add extracurricular expense provisions to the support order.
What Happens When Parents Disagree About Activities
Disagreements about extracurricular activities frequently arise when parents have different values about activities, different financial situations, or different levels of involvement in the child's interests. Wyoming courts analyze disputed activity requests under the best interests of the child standard, considering whether the activity promotes the child's physical, emotional, and educational development.
Common disputes and typical court resolutions:
| Dispute Type | Typical Court Resolution |
|---|---|
| One parent refuses to pay share | Court orders payment and may find contempt for repeated refusal |
| Parent enrolls child without consent | Non-consenting parent not required to pay if decree requires mutual approval |
| Parents disagree on activity value | Court considers child's age, interest level, and established participation pattern |
| Activity costs exceed family budget | Court may limit total annual spending or require percentage caps |
| Activity conflicts with custody time | Court examines which parent's time is affected and may adjust schedule |
| Travel requirements exceed reasonableness | Court may limit travel distance or require cost-sharing for transportation |
Under Wyo. Stat. § 20-2-307(b)(xii), courts consider whether either parent has violated any provision of the divorce decree, including visitation provisions, when making support deviation decisions. A parent who consistently undermines the other's custody time for extracurricular activities may face unfavorable rulings on activity cost disputes.
Tax Implications of Extracurricular Expense Payments
Extracurricular expenses paid as part of child support are not tax-deductible for the paying parent and are not taxable income for the receiving parent under IRS rules. However, the way expenses are structured can affect tax outcomes. Payments made directly to activity providers (sports leagues, music schools, camps) rather than to the other parent may have different documentation requirements.
Tax considerations for extracurricular expenses include:
- Direct payments to third parties are generally treated the same as support payments
- Dependent care credits may apply if activities qualify as child care (e.g., after-school programs)
- The parent claiming the child as a dependent can claim education credits for qualifying expenses
- Medical-related activities (therapeutic riding, physical therapy sports) may qualify as medical expenses
- Careful record-keeping protects both parents during IRS audits
Parents should maintain detailed records of all extracurricular payments including receipts, canceled checks, electronic payment confirmations, and written agreements about cost-sharing. The IRS may require documentation for any disputed payments if either parent claims related deductions or credits.
Enforcement When a Parent Refuses to Pay Activity Costs
When a parent fails to pay their court-ordered share of extracurricular expenses, Wyoming provides enforcement mechanisms through the district court and the Wyoming Child Support Program. Enforcement options depend on whether the extracurricular costs were included in the formal support order or were part of a separate written agreement between parents.
Enforcement steps for unpaid extracurricular costs:
- Send written demand for payment with copies of receipts and the relevant decree provision
- File a Motion for Contempt if the parent fails to pay within 30 days of demand
- Request attorney fees and costs for enforcement under Wyo. Stat. § 20-2-307
- Seek wage garnishment through the Wyoming Child Support Program for ongoing violations
- Request a lien on the non-paying parent's property or assets for accumulated unpaid amounts
Contempt of court findings can result in fines, jail time, and additional payment obligations. Courts generally order the violating parent to pay the other parent's attorney fees for enforcement proceedings, which typically range from $1,500 to $5,000 for contempt actions.
The Wyoming Child Support Program can assist with enforcement of activity expenses only if those expenses are formally included in the child support order. Informal agreements between parents about activity cost-sharing are not enforceable through the state program.
Special Considerations for High-Income Families
High-income families in Wyoming face unique issues when allocating extracurricular costs because standard child support guidelines may not adequately address their children's established lifestyle. Under Wyo. Stat. § 20-2-307, courts may deviate from presumptive support amounts when application would be unjust given the family's circumstances.
For families with combined income exceeding $200,000 annually, courts consider:
- The children's accustomed standard of living during the marriage
- Activities the children participated in before the divorce filing
- Whether activities are reasonably necessary to maintain the children's lifestyle
- The total cost of activities relative to each parent's income
- Whether activity expenses were typical for the family's income level
High-income families often negotiate extracurricular provisions separately from basic child support, establishing annual activity budgets of $5,000 to $25,000 per child depending on family income and the children's established interests. These agreements may include provisions for private coaching, elite travel teams, specialized equipment, and competition fees that exceed typical middle-income family expenses.
Practical Tips for Negotiating Activity Cost Agreements
Successful negotiation of extracurricular cost agreements requires both parents to focus on the children's genuine interests rather than using activities as leverage in the divorce. Parents who approach activity negotiations collaboratively typically save $5,000 to $15,000 in attorney fees compared to those who litigate every activity decision.
Effective negotiation strategies include:
- Start with the children's current activities and established interests
- Use a shared spreadsheet or app to track all activity expenses in real-time
- Agree on a maximum annual budget before discussing specific activities
- Build in flexibility for new activities that emerge as children grow
- Include a mediation requirement before court intervention for disputes
- Specify a process for handling unexpected costs (tournament fees, equipment repairs)
- Address how to handle activities that conflict with custody schedules
Many Wyoming parents use co-parenting apps like OurFamilyWizard or Cozi to track activity expenses, share calendars, and document reimbursement requests. Courts increasingly accept app records as evidence in extracurricular cost disputes.
Frequently Asked Questions
Does Wyoming child support automatically cover extracurricular activities?
No, Wyoming child support under Wyo. Stat. § 20-2-304 covers basic expenses including housing, food, clothing, and reasonable recreation, but does not automatically include costly extracurricular programs. Activities like travel sports, private lessons, and competitive programs require separate allocation in the divorce decree or a modified support order.
How do Wyoming courts decide which parent pays for sports fees?
Wyoming courts typically divide extracurricular costs proportionally based on each parent's percentage of combined income using the income shares model. If one parent earns 65% of combined income, they would pay 65% of agreed-upon activity costs. Courts consider the child's established participation pattern and whether both parents consented to the activity.
Can I get my child support modified to include extracurricular expenses?
Yes, under Wyo. Stat. § 20-2-311, you can petition for modification if circumstances have changed enough to alter support by 20% or more. Additionally, every three years either parent may request a review without showing changed circumstances. The Wyoming Child Support Program at (307) 777-5300 provides free modification assistance.
What is the Christensen Deviation in Wyoming child support?
The Christensen Deviation is a Wyoming court doctrine that allows adjustment of child support based on payment of extraordinary expenses above basic support, including extracurricular activities, sporting equipment, and school-related costs. This deviation can change support obligations by more than 50% and requires detailed documentation of additional expenses paid.
What happens if my ex refuses to pay their share of activity costs?
If extracurricular costs are included in your court order and your ex refuses to pay, you can file a Motion for Contempt in district court. Courts can order payment, impose fines, garnish wages, and award you attorney fees for enforcement. Repeated violations may result in jail time for contempt of court.
Do both parents have to agree before enrolling a child in activities?
Wyoming law does not require mutual consent for extracurricular enrollment, but your divorce decree should specify approval requirements. Courts typically favor agreements requiring both parents to approve activities costing more than $250-500 per season. Without mutual consent provisions, one parent cannot force the other to pay for activities they did not approve.
How much do extracurricular activities typically cost in Wyoming divorces?
Extracurricular costs vary widely based on the activity type: community sports leagues cost $50-200 per season, travel teams cost $2,000-8,000 annually, private lessons cost $100-300 monthly, and competitive programs can exceed $10,000 per year. Wyoming families typically allocate $1,500-5,000 annually per child for extracurricular activities.
Can I claim extracurricular expenses on my taxes?
Extracurricular expenses paid as child support are not tax-deductible, but certain costs may qualify for dependent care credits if the activity serves as child care. The parent claiming the child as a dependent may claim education credits for qualifying expenses. Medical-related activities may qualify as deductible medical expenses.
What if my child wants to quit an activity we agreed to pay for?
Most activity cost agreements should address early termination. Courts generally do not require continued payment if the child genuinely wants to stop participating. However, if one parent encouraged the child to quit, courts may require that parent to reimburse fees already paid. Include provisions for handling mid-season withdrawals in your decree.
How do I document extracurricular expenses for court?
Maintain detailed records including registration receipts, equipment purchase receipts, tournament fee documentation, travel expense records, and any written communications about cost-sharing. Use co-parenting apps or shared spreadsheets to track expenses in real-time. Courts accept app records and electronic documentation as evidence in extracurricular cost disputes.