The Wyoming Supreme Court issued an opinion December 10, 2025, affirming a district court's interpretation and enforcement of a postnuptial agreement in the divorce case *Jones v. Young* (2025 WY 130). The decision resolves a complex marital dissolution dispute involving property valuation and distribution issues that generated both an appeal and cross-appeal.
Jeremy D. Jones challenged the Albany County District Court's interpretation of the parties' postnuptial agreement and its valuation and distribution of marital property. His wife, Bethany D. Young, filed a cross-appeal challenging the trial court's ruling that the postnuptial agreement was enforceable. The Wyoming Supreme Court affirmed the district court on all issues.
The case centered on three primary legal questions: whether the district court erred in ruling the postnuptial agreement was enforceable; whether the court correctly interpreted the agreement to allow judicial discretion in marital property distribution; and whether the court abused its discretion in calculating the value of the marital residence.
The parties married July 5, 2014, and had no children together. The case was heard before Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and Hill. Chief Justice Boomgaarden authored the opinion for the court.
Jones was represented by Jordan A. Surber of Coal Creek Law LLP in Cheyenne, who argued the case before the high court. Young's legal team included Abigail E. Fournier and Linda J. Steiner of Steiner, Fournier, Zook & Case, LLC, also based in Cheyenne. Attorney Zook presented oral arguments for Young.
The dispute arose from the parties' postnuptial agreement, a contract entered into after marriage that typically governs property rights and financial obligations in the event of divorce. Unlike prenuptial agreements signed before marriage, postnuptial agreements are created during the marriage and can address changing financial circumstances or relationship dynamics.
Jones argued the district court misinterpreted the postnuptial agreement's provisions regarding property distribution. He contended the trial court erred in how it valued and divided marital assets, particularly challenging the valuation methodology used for the marital residence. The specific valuation disputes involved technical questions about property appraisal methods and the court's discretionary authority in determining fair market value.
Meanwhile, Young's cross-appeal challenged the fundamental enforceability of the postnuptial agreement itself. She argued the agreement should be deemed unenforceable, which would have required the court to distribute marital property according to Wyoming's equitable distribution statutes rather than the agreement's terms.
The Wyoming Supreme Court's affirmance means the district court properly found the postnuptial agreement valid and enforceable under state law. The high court also determined the trial court correctly interpreted the agreement's language regarding property distribution and did not abuse its discretion in valuing the marital residence.
This decision provides important guidance for Wyoming family law practitioners and divorcing couples regarding postnuptial agreement enforcement. The ruling clarifies that properly executed postnuptial agreements will be upheld by Wyoming courts when they meet legal requirements for validity and enforceability.
The case also establishes precedent for how courts should interpret postnuptial agreement provisions that grant judicial discretion in property matters. The Wyoming Supreme Court's affirmance suggests trial courts retain authority to exercise reasonable discretion in property valuation and distribution even when bound by postnuptial agreement terms.
For property valuation disputes, the decision reinforces that appellate courts will not overturn trial court valuations absent clear abuse of discretion. This standard gives trial judges considerable deference in weighing appraisal evidence and determining fair market values for marital assets.
The *Jones v. Young* decision reflects Wyoming's approach to balancing contractual freedom in marriage with judicial oversight of divorce proceedings. By enforcing the postnuptial agreement while affirming the trial court's discretionary authority, the Wyoming Supreme Court maintained both parties' ability to structure their financial relationship through contract and the court's role in ensuring fair divorce outcomes.
The opinion was designated as subject to formal revision before publication in Pacific Reporter Third, indicating it will become part of Wyoming's published legal precedent once finalized. The case numbers S-25-0050 and S-25-0051 reflect the dual nature of the proceedings, with both the initial appeal and cross-appeal receiving separate docket numbers.
This ruling adds to Wyoming's body of family law precedent regarding postnuptial agreements and provides guidance for future cases involving similar contractual and property valuation disputes in divorce proceedings.