guez-Williams v. Johnson, 2024 WY 16, 542

P.3d 632, 2024 Wyo. LEXIS 16 (Wyo. 2024). Child Support Enforcement Action. — The department of family services may bring an action in its own name to enforce a child support order, without regard to the obligee’s status as a recipient or non-recipient of public assistance. Department of Family Servs. v. Pe- terson, 960 P.2d 1022, 1998 Wyo. LEXIS 115 (Wyo. 1998). Grandparents’ visitation claims may be litigated by intervening in divorce pro- ceedings post-decree. — Grandparents’ visi- tation claims under former § 20-2-113(c) (now see § 20-7-101) may be litigated by indepen- dent proceedings; or, pursuant to the provisions of subdivision (b), by intervening in a divorce proceeding post-decree, in the exercise of dis- cretion of the court, when the requisite facts under the rule exist. Nation v. Nation, 715 P.2d 198, 1986 Wyo. LEXIS 504 (Wyo. 1986). Impairment of ability to protect interest warranting intervention must be practi- cal. — The impediment or impairment of the ability to protect one’s interest which would warrant intervention under subdivision (a)(2) must be a practical one, but it need not be a legal one. The application of the doctrine of stare decisis or res judicata is a practical dis- advantage. James S. Jackson Co. v. Horseshoe Creek, Ltd., 650 P.2d 281, 1982 Wyo. LEXIS 378 (Wyo. 1982). Limits on right of counties to inter- vene.— Wyo. Stat. Ann. § 39-11-102.1(c) does not confer upon counties the requisite interest to intervene as of right in a contested case before the Wyoming Board of Equalization brought by a taxpayer against the Wyoming Department of Revenue challenging substan- tive methodology decisions by the Department regarding valuation. The Department erred by allowing the county to intervene in a deficiency dispute with a taxpayer since the county’s in-