Wyoming Case Commentaries

Wyoming Adoption Procedure: Unmarried Adults May Not File a Joint Adoption Petition Under § 1-22-104(b), But May File Separate Petitions Subject to Consolidation

Date: Feb 21, 2026

Wyoming Adoption Procedure: Unmarried Adults May Not File a Joint Adoption Petition Under § 1-22-104(b), But May File Separate Petitions Subject to Consolidation Introduction In In the Matter of the...

Wyoming Conditional Pleas: If Any Reserved Issue Is Non-Dispositive, the Entire Rule 11(a)(2) Plea Is Invalid

Date: Feb 18, 2026

Wyoming Conditional Pleas: If Any Reserved Issue Is Non-Dispositive, the Entire Rule 11(a)(2) Plea Is Invalid I. Introduction In Sabrina Kaylee Sunshine Stone v. the State of Wyoming, 2026 WY 22...

Rightful LLC Expulsion Does Not Extinguish Transferable Ownership for Conversion; Defamation Per Se Damages May Exceed Nominal Amounts

Date: Feb 18, 2026

Rightful LLC Expulsion Does Not Extinguish Transferable Ownership for Conversion; Defamation Per Se Damages May Exceed Nominal Amounts Introduction In John A. McCall, Jr. v. Best of the West...

Section 3 Disqualification in Wyoming Requires State-Law Enforcement; Declaratory Judgment Cannot Remove a Statewide Officer

Date: Feb 14, 2026

Section 3 Disqualification in Wyoming Requires State-Law Enforcement; Declaratory Judgment Cannot Remove a Statewide Officer 1. Introduction In Timothy K. Newcomb v. Chuck Gray, Wyoming Secretary of...

Harmless Statutory Mislabeling in Expungement and Waiver of “Substantial Danger” Challenges; Registration Lapses Not a Categorical Bar to Termination

Date: Feb 12, 2026

Harmless Statutory Mislabeling in Expungement and Waiver of “Substantial Danger” Challenges; Registration Lapses Not a Categorical Bar to Termination I. Introduction The State of Wyoming v. Dixon...

McCalla v. State (2026 WY 18): Self-Defense Immunity Requires Competent Evidence; Reengagement Makes Defendant the Initial Aggressor; Conditional Plea Limits Appellate Review

Date: Feb 7, 2026

Self-Defense Immunity in Wyoming: Allegations Don’t Make a Prima Facie Case; Reengagement Creates “Initial Aggressor” Status; Conditional Pleas Confine Discovery Appeals Case: Cody Joseph Mccalla v....

Wyoming Will-Contest Procedure: A § 2-6-301 Petition Need Not Be a New Civil Action Separate from the Probate Docket

Date: Feb 7, 2026

Wyoming Will-Contest Procedure: A § 2-6-301 Petition Need Not Be a New Civil Action Separate from the Probate Docket Introduction In In the Matter of the Estate of Lloyd Haack, Deceased: Howard E....

Generic “No Third-Party Beneficiaries” Clauses Do Not Defeat Plausible Intended-Beneficiary Claims at the Pleading Stage; BRC Project “Administration” May Include Construction Oversight

Date: Feb 4, 2026

Generic “No Third-Party Beneficiaries” Clauses Do Not Defeat Plausible Intended-Beneficiary Claims at the Pleading Stage; BRC Project “Administration” May Include Construction Oversight Introduction...

Authentication Requires Consistency Between a Witness’s Recollection and the Exhibit: Trial Courts May Exclude a “Bill of Sale” When the Proffered Document Does Not Match the Witness’s Description

Date: Jan 27, 2026

Authentication Requires Consistency Between a Witness’s Recollection and the Exhibit: Trial Courts May Exclude a “Bill of Sale” When the Proffered Document Does Not Match the Witness’s Description 1....

Probable Cause to Search an Entire Single-Family Mobile Home Survives Franks-Omission Claims When the Suspect Has Home-Wide Access

Date: Jan 25, 2026

Probable Cause to Search an Entire Single-Family Mobile Home Survives Franks-Omission Claims When the Suspect Has Home-Wide Access Introduction In Chad Everette Urrutia v. The State of Wyoming, 2026...

Contingent Rule 14 Third-Party Claims Must Still Survive Rule 56: Speculation and Incomplete Discovery Do Not Defeat Summary Judgment Without Rule 56(d) Compliance

Date: Jan 25, 2026

Contingent Rule 14 Third-Party Claims Must Still Survive Rule 56: Speculation and Incomplete Discovery Do Not Defeat Summary Judgment Without Rule 56(d) Compliance Case: Sletten Construction of...

Recent, Temporary Parental Improvements Do Not Defeat Termination Under Wyo. Stat. § 14-2-309(a)(v) After 15 of 22 Months in Foster Care

Date: Jan 25, 2026

Recent, Temporary Parental Improvements Do Not Defeat Termination Under Wyo. Stat. § 14-2-309(a)(v) After 15 of 22 Months in Foster Care Introduction Case: In the Matter of the Termination of...

Probation Revocation: Skipping the Dispositional Phase (and Mitigation Right) Is Plain Error

Date: Jan 23, 2026

Probation Revocation: Skipping the Dispositional Phase (and Mitigation Right) Is Plain Error Introduction In Jeremy S. Velasquez v. The State of Wyoming, 2026 WY 11 (Jan. 22, 2026), the Wyoming...

Wyoming Felony Expungement Limited to “Records of Conviction”: Deferred-Prosecution Dismissals Are Ineligible Under Wyo. Stat. § 7-13-1502

Date: Jan 16, 2026

Wyoming Felony Expungement Limited to “Records of Conviction”: Deferred-Prosecution Dismissals Are Ineligible Under Wyo. Stat. § 7-13-1502 Case: Russell Lee Lynch v. The State of Wyoming, 2026 WY 8...

Attempted Witness Intimidation Under Wyo. Stat. Ann. § 6-5-305(a) Requires Specific Intent and a Proven Nexus to the Witness’s Duty

Date: Jan 15, 2026

Attempted Witness Intimidation Under Wyo. Stat. Ann. § 6-5-305(a) Requires Specific Intent and a Proven Nexus to the Witness’s Duty Case: Steve Brandon Brown v. The State of Wyoming, 2026 WY 6 (Wyo....

Reasonable Reunification Efforts for Incarcerated Parents: Child Permanency Justifies Switching from Reunification to Adoption

Date: Jan 9, 2026

Reasonable Reunification Efforts for Incarcerated Parents: Child Permanency Justifies Switching from Reunification to Adoption 1. Introduction In In the Interest Of: DC, minor child, AC v. The State...

Minor Late Disclosure Without Prejudice Does Not Require Exclusion; CAMA Assessments Retain a Strong Presumption of Validity

Date: Jan 8, 2026

Minor Late Disclosure Without Prejudice Does Not Require Exclusion; CAMA Assessments Retain a Strong Presumption of Validity Introduction In H. Kenneth Johnston II v. Todd Ernst, in his official...

Wyoming Article 1, § 38 Protects Abortion as a Fundamental Health Care Decision; Strict Scrutiny Applies; Salerno “No-Set-of-Circumstances” Facial-Challenge Standard Rejected

Date: Jan 7, 2026

Wyoming Article 1, § 38 Protects Abortion as a Fundamental Health Care Decision; Strict Scrutiny Applies; Salerno “No-Set-of-Circumstances” Facial-Challenge Standard Rejected Case: State of Wyoming;...

Refusing to Decide as Abuse of Discretion: Hale & Ringen v. City of Laramie and the Duty to Adjudicate Rule 60(b) Motions to Modify Injunctions

Date: Dec 16, 2025

Refusing to Decide as Abuse of Discretion: Hale & Ringen v. City of Laramie and the Duty to Adjudicate Rule 60(b) Motions to Modify Injunctions I. Introduction In Timothy Hale and Sonja Ringen v....

Prejudgment Interest as a Question of Law for the Court: Commentary on Russ & Debi Ropken v. YJ Construction, Inc. (2025 WY 131)

Date: Dec 12, 2025

Prejudgment Interest as a Question of Law for the Court: Commentary on Russ & Debi Ropken v. YJ Construction, Inc., 2025 WY 131 I. Introduction The Wyoming Supreme Court’s decision in Russ Ropken and...