Wyoming Case Commentaries

Final Judgment as Implicit Denial of Unruled Rule 37 Sanctions Motions (and the Need for an Evidentiary Record) in Wyoming

Date: Jul 17, 2026

Final Judgment as Implicit Denial of Unruled Rule 37 Sanctions Motions (and the Need for an Evidentiary Record) in Wyoming 1. Introduction In In the Matter of the Estate of Robert P. Dykes, Deceased:...

Wyoming WAPA Review: Arbitrary-and-Capricious Scrutiny Applies to Agency Legislative (Rulemaking) Action

Date: Jul 15, 2026

Wyoming WAPA Review: Arbitrary-and-Capricious Scrutiny Applies to Agency Legislative (Rulemaking) Action Decision: Warren Livestock, LLC, et al. v. Board of County Commissioners, County of Albany,...

Wyoming Applies Arbitrary-and-Capricious Review to Agency Legislative Rulemaking Under the WAPA (APOZ Aquifer-Protection Zoning Upheld)

Date: Jul 15, 2026

Wyoming Applies Arbitrary-and-Capricious Review to Agency Legislative Rulemaking Under the WAPA (APOZ Aquifer-Protection Zoning Upheld) 1. Introduction In Warren Livestock, LLC, et al. v. Board of...

Totality-of-the-Circumstances Nexus in Search-Warrant Affidavits: Common-Sense Inferences and Presumed Reliability of Law-Enforcement Sources

Date: Jul 15, 2026

Totality-of-the-Circumstances Nexus in Search-Warrant Affidavits: Common-Sense Inferences and Presumed Reliability of Law-Enforcement Sources Introduction In Christopher Allen Campbell v. The State...

Wyoming Settlement Enforcement Rule: No Enforcement Where Mediation Memorandum Leaves Essential Implementation Terms Unagreed

Date: Jul 10, 2026

Wyoming Settlement Enforcement Rule: No Enforcement Where Mediation Memorandum Leaves Essential Implementation Terms Unagreed Introduction In Amy Cross and Cross Ranch Land, LLC v. Lisa Albright,...

Wyoming Boys’ School Cannot Be Used to Detain Alleged Delinquents Pre‑Adjudication

Date: Jul 8, 2026

Wyoming Boys’ School Cannot Be Used to Detain Alleged Delinquents Pre‑Adjudication 1. Introduction In the Interest of RCR, a Minor Child: State of Wyoming, Department of Family Services; Wyoming...

Wyoming Boys’ School Cannot Be Used for Pre-Adjudication Juvenile Detention Under the Juvenile Justice Act

Date: Jul 8, 2026

Wyoming Boys’ School Cannot Be Used for Pre-Adjudication Juvenile Detention Under the Juvenile Justice Act 1. Introduction In In the Interest of RCR, a minor child, STATE OF WYOMING, DEPARTMENT OF...

Wyoming Courts Cannot Condition Public-Defender Representation on Forced Pretrial Liquidation of a Defendant’s Assets

Date: Jul 8, 2026

Wyoming Courts Cannot Condition Public-Defender Representation on Forced Pretrial Liquidation of a Defendant’s Assets Introduction In John Robert Allen v. The State of Wyoming, 2026 WY 72, the...

Summary Affirmance for Non-Cogent Appellate Briefing Under W.R.A.P. 7.01 and 7.03 (Even When Represented by Counsel)

Date: Jul 7, 2026

Summary Affirmance for Non-Cogent Appellate Briefing Under W.R.A.P. 7.01 and 7.03 (Even When Represented by Counsel) 1. Introduction Joshua Michael Idler v. Ashley Nicole Idler, 2026 WY 71 (Wyo. July...

Temporal Association Is Not Causation: Proving a Second Compensable Injury from a Medication Dosage Increase

Date: Jul 4, 2026

Temporal Association Is Not Causation: Proving a Second Compensable Injury from a Medication Dosage Increase 1. Introduction In Sam Mcdonald v. State of Wyoming, Ex Rel. Department of Workforce...

Ribera v. Ribera (2026 WY 69): Timely, Particularized “Good Cause” for Rule 35 Custody Exams; Valuation of Suspicious Post-Filing Transfers to a Nonprofit in Property Division

Date: Jul 3, 2026

Timely, Particularized “Good Cause” Is Required for Rule 35 Psychological Exams in Custody Cases; Suspicious Post-Filing Transfers to a Nonprofit May Be Valued in the Marital Estate Introduction In...

Curative Opportunity Defeats Plain-Error Due Process Claims in Wyoming Child-Protection Adjudications

Date: Jun 24, 2026

Curative Opportunity Defeats Plain-Error Due Process Claims in Wyoming Child-Protection Adjudications 1. Introduction In In the Interest Of: AC and BI, Minor Children, AI v. The State of Wyoming,...

Post-Removal Hair Follicle Tests Are Relevant at Neglect Adjudication When They Encompass the Petition Date

Date: Jun 22, 2026

Post-Removal Hair Follicle Tests Are Relevant at Neglect Adjudication When They Encompass the Petition Date 1. Introduction Case: In the Interest Of: AC and BI, Minor Children, JC v. The State of...

When “Concurrent Sentences” in a Plea Deal Is Only a Rule 11(e)(1)(B) Recommendation (Not a Rule 11(e)(1)(C) Specific-Sentence Agreement)

Date: Jun 22, 2026

When “Concurrent Sentences” in a Plea Deal Is Only a Rule 11(e)(1)(B) Recommendation (Not a Rule 11(e)(1)(C) Specific-Sentence Agreement) Case: Michael Scott Hughes v. The State of Wyoming Citation:...

Particularized Knowledge of a High-Probability Hazard Is Required to Pierce Co-Employee Immunity Under Wyo. Stat. Ann. § 27-14-104(a)

Date: Jun 19, 2026

Particularized Knowledge of a High-Probability Hazard Is Required to Pierce Co-Employee Immunity Under Wyo. Stat. Ann. § 27-14-104(a) Introduction In Dusty Courtney v. Kenneth Meyer, 2026 WY 67 (June...

Rule 41(g) After Sentencing: State Rebuts Presumptive Entitlement by Showing Property Is Likely Stolen; Movant Must Then Prove Lawful Possession

Date: Jun 13, 2026

Rule 41(g) After Sentencing: State Rebuts Presumptive Entitlement by Showing Property Is Likely Stolen; Movant Must Then Prove Lawful Possession 1. Introduction In Jesse Alexander Mostaert v. The...

“Husband and Wife” in a Quiet Title Judgment—Including the Caption—Manifests Tenancy by the Entirety (and § 34-1-140(b) Codifies, Not Changes, Wyoming Law)

Date: Jun 10, 2026

“Husband and Wife” in a Quiet Title Judgment—Including the Caption—Manifests Tenancy by the Entirety (and § 34-1-140(b) Codifies, Not Changes, Wyoming Law) 1. Introduction In Natusha Lewis v. Brenda...

Exhibit-Listed Retirement Accounts Remain Subject to a Postnuptial Retirement Division Formula

Date: Jun 5, 2026

Exhibit-Listed Retirement Accounts Remain Subject to a Postnuptial Retirement Division Formula Introduction In Andrea K. Smerski f/k/a Andrea K. Lemon v. Darren M. Lemon, 2026 WY 61 (June 4, 2026),...

Wyoming Rule 55(c) “Good Cause” Requires a Clearly Articulated Rule 60(b) Ground and Cogent, Cited Argument—Courts Need Not Supply Missing Analysis

Date: Jun 5, 2026

Wyoming Rule 55(c) “Good Cause” Requires a Clearly Articulated Rule 60(b) Ground and Cogent, Cited Argument—Courts Need Not Supply Missing Analysis I. Introduction Case: Josiah Moran, Conservator of...

Wyoming Post-Majority Support Requires Proof a Disability Renders the Adult Child Incapable of Self-Support

Date: Jun 5, 2026

Wyoming Post-Majority Support Requires Proof a Disability Renders the Adult Child Incapable of Self-Support Case: Jonathan Merrick Causey, a Disabled Adult Child, and Tracey Causey, Court Appointed...