Wyoming Case Commentaries

Wyoming Must Fund True-Cost Teacher Salaries and Make Cumulative Annual Inflation Adjustments (ECAs) in the Legislative Model

Date: Sep 19, 2026

Wyoming Must Fund True-Cost Teacher Salaries and Make Cumulative Annual Inflation Adjustments (ECAs) in the Legislative Model Case: The State of Wyoming v. Wyoming Education Association, a Wyoming...

Wyoming Presentence Credit Rule for Out-of-State Confinement on Independent Charges & Notice-of-Appeal Jurisdiction for Post-Notice Orders

Date: Sep 16, 2026

Out-of-State Jail Time Is Not Credited When Independent Charges Would Have Kept the Defendant Confined; Post-Notice Orders Require a Separate/Amended Notice of Appeal Brian Joseph Melber v. The State...

No Double Presentence Credit Across Separate Dockets When Confinement Is Attributable to Probation Revocation

Date: Sep 5, 2026

No Double Presentence Credit Across Separate Dockets When Confinement Is Attributable to Probation Revocation Case: Yzail Ashton Gauna v. The State of Wyoming, 2026 WY 97 (Wyo. Sept. 3, 2026) Court:...

No Double Credit for Jail Time Across Separate Dockets Unless Confinement Was Solely for Unposted Bond

Date: Sep 5, 2026

No Double Credit for Jail Time Across Separate Dockets Unless Confinement Was Solely for Unposted Bond Case: Yzail Ashton Gauna v. The State of Wyoming, 2026 WY 97 (Wyo. Sept. 3, 2026) 1....

Wyoming Rule: Unraised K9 Free-Air Sniff Challenges Are Waived Absent “Impediment”-Based Good Cause; Coded Drug Messages Admissible as 404(b) Context for Intent to Distribute

Date: Sep 3, 2026

Wyoming Rule: Unraised K9 Free-Air Sniff Challenges Are Waived Absent “Impediment”-Based Good Cause; Coded Drug Messages Admissible as 404(b) Context for Intent to Distribute Introduction In Marvin...

Preliminary Injunction Orders Must Remain Nonfinal Absent Rule 65(a)(2) Consolidation Notice

Date: Aug 27, 2026

Preliminary Injunction Orders Must Remain Nonfinal Absent Rule 65(a)(2) Consolidation Notice Case: Dillinger's LLC, a Wyoming Limited Liability Company and Ryan Clement, an Individual v. CR-GTD, LLC,...

Stability and Practical Feasibility Control Initial Long-Distance Custody Determinations Despite Both Parents’ Fitness

Date: Aug 18, 2026

Stability and Practical Feasibility Control Initial Long-Distance Custody Determinations Despite Both Parents’ Fitness 1. Introduction In Brian Swindler v. Leah Bright, 2026 WY 90 (Wyo. Aug. 11,...

Limited-Remand Compliance and Enforceable Personal Oral Guarantees as Separate Contracts

Date: Aug 18, 2026

Limited-Remand Compliance and Enforceable Personal Oral Guarantees as Separate Contracts Introduction In Paul J. Sorum v. Mike Sikorski and Big Sky Limited of Wyoming, a Wyoming Corporation, 2026 WY...

Lopez v. Ritter (2026 WY 89): Due Diligence as a Jurisdictional Prerequisite to § 1-6-301 Service; Nonjurisdictional Due Process Service Objections Are Waived; Appellate Review Limited to Orders Named in the Notice of Appeal

Date: Aug 13, 2026

Due Diligence Is Jurisdictional for Wyoming Nonresident Motorist Service; Nonjurisdictional Due Process Service Objections Are Waived; Appellate Review Is Limited to Orders Named in the Notice of...

Substantial Independent Evidence Defeats Strickland Prejudice in W.R.A.P. 21 New-Trial Motions

Date: Aug 8, 2026

Substantial Independent Evidence Defeats Strickland Prejudice in W.R.A.P. 21 New-Trial Motions 1. Introduction In Rene Irisrose Daniels v. The State of Wyoming, 2026 WY 88, the Wyoming Supreme Court...

Substantial Independent Evidence Defeats Strickland Prejudice in W.R.A.P. 21 Ineffective-Assistance New-Trial Motions

Date: Aug 8, 2026

Substantial Independent Evidence Defeats Strickland Prejudice in W.R.A.P. 21 Ineffective-Assistance New-Trial Motions 1. Introduction In Rene Irisrose Daniels v. The State of Wyoming, 2026 WY 88, the...

Contempt for Frustrating Court-Ordered Joint Tax Filing: Contextual Construction of “Withdraw” and Compensatory IRS Penalties

Date: Aug 7, 2026

Contempt for Frustrating Court-Ordered Joint Tax Filing: Contextual Construction of “Withdraw” and Compensatory IRS Penalties I. Introduction In Guy Morrison III v. Tami Hinson-Morrison, 2026 WY 87...

“Masturbation” in Wyoming Child Sexual Exploitation Includes Digital Penetration and Sex-Device Penetration; Unanimity Concerns Defeated by Count-Specific Instructions

Date: Jul 31, 2026

“Masturbation” in Wyoming Child Sexual Exploitation Includes Digital Penetration and Sex-Device Penetration; Unanimity Concerns Defeated by Count-Specific Instructions Introduction In William John...

Venue for Vulnerable-Adult Exploitation Lies Where the Property Is Located and the Transfer Takes Effect; Restitution May Include Replacement Clothing When Defendant’s Control Prevents Access

Date: Jul 27, 2026

Venue for Vulnerable-Adult Exploitation Lies Where the Property Is Located and the Transfer Takes Effect; Restitution May Include Replacement Clothing When Defendant’s Control Prevents Access 1....

Conditional Plea Waiver in Wyoming: Ineffective Assistance Claims Require a Voluntariness Nexus; Kitzke Limited

Date: Jul 27, 2026

Conditional Plea Waiver in Wyoming: Ineffective Assistance Claims Require a Voluntariness Nexus; Kitzke Limited Introduction In Thomas Avery Glenn v. The State of Wyoming, 2026 WY 85, the Wyoming...

Household-Control and Grooming Evidence as Admissible Rule 404(b) Proof of Motive/Plan in Child Sexual-Abuse Prosecutions

Date: Jul 20, 2026

Household-Control and Grooming Evidence as Admissible Rule 404(b) Proof of Motive/Plan in Child Sexual-Abuse Prosecutions Case: Steven Randall Marler v. The State of Wyoming Citation: 2026 WY 83...

Waiver of Appellate Review Without an Offer of Proof After a Motion in Limine Excludes Undisclosed Damages Evidence

Date: Jul 18, 2026

Waiver of Appellate Review Without an Offer of Proof After a Motion in Limine Excludes Undisclosed Damages Evidence Introduction In William Gordon Lacher v. Terry Case; Case Concrete, LLC; and Case...

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination

Date: Jul 18, 2026

Wyoming TPR Rule: No “Reasonable Efforts” Prerequisite Under § 14-2-309(a)(v), and Unchallenged Independent Grounds Sustain Termination 1. Introduction In In the Matter of the Termination of Parental...

Premature Willfulness Findings in Probation Revocations Are Error but Not Plain Error Absent Material Prejudice (Smith v. State)

Date: Jul 17, 2026

Premature Willfulness Findings in Probation Revocations Are Error but Not Plain Error Absent Material Prejudice (Smith v. State) 1. Introduction In David Lee Smith v. The State of Wyoming, 2026 WY...

Termination Under Wyo. Stat. Ann. § 14-2-309(a)(v) Requires No “Reasonable Efforts” Showing; Neglect-Statute Efforts Provision Inapplicable

Date: Jul 17, 2026

Termination Under Wyo. Stat. Ann. § 14-2-309(a)(v) Requires No “Reasonable Efforts” Showing; Neglect-Statute Efforts Provision Inapplicable Introduction In In the Matter of the Termination of...