Wyoming Case Commentaries

Invited Error Waives Instructional Objections; Single-Count Third-Degree Sexual Abuse Requires No Act-Specific Jury Instruction

Date: Oct 9, 2025

Invited Error Waives Instructional Objections; Single-Count Third-Degree Sexual Abuse Requires No Act-Specific Jury Instruction Introduction This commentary examines the Supreme Court of Wyoming’s...

Clear-and-Convincing Proof and the “Offense Giving Rise” in Wyoming Civil Forfeiture: Mickulin v. State (2025 WY 106)

Date: Oct 1, 2025

Clear-and-Convincing Proof and the “Offense Giving Rise” in Wyoming Civil Forfeiture Case: In the Matter of U.S. Currency Totaling $54,226.00: Ronald S. Mickulin v. State of Wyoming Citation: 2025 WY...

Medically Contested Causation Must Be Referred to the Wyoming Medical Commission Based on the Record at the Time of Referral: Commentary on Polzer v. State ex rel. Department of Workforce Services, Workers’ Compensation Division (2025 WY 104)

Date: Sep 27, 2025

Medically Contested Causation Must Be Referred to the Wyoming Medical Commission Based on the Record at the Time of Referral Comprehensive Commentary on Joseph Daniel Polzer v. State of Wyoming, ex...

Concurrent Permanency Planning Is Discretionary, Not Mandatory, Under Wyo. Stat. § 14-3-440: Wyoming Supreme Court Affirms Shift to Adoption in In the Interest of LC (2025 WY 105)

Date: Sep 27, 2025

Concurrent Permanency Planning Is Discretionary, Not Mandatory, Under Wyo. Stat. § 14-3-440: Wyoming Supreme Court Affirms Shift to Adoption in In the Interest of LC (2025 WY 105) Introduction The...

Wyoming Supreme Court Bars Double Counting of Pass‑Through Business Income in Child Support Calculations: Stenson v. Stenson (2025 WY 102)

Date: Sep 25, 2025

Wyoming Supreme Court Bars Double Counting of Pass‑Through Business Income in Child Support Calculations Case: Matthew R. Stenson v. Nikole M. Stenson, 2025 WY 102 (Wyo. Sept. 23, 2025) Court:...

Lake v. State: Late-Disclosed Impeachment Evidence During Trial Is Not Brady “Suppression,” and Child-Witness Competency Turns on Mental Ability, Not Detailed Recall

Date: Sep 13, 2025

Lake v. State: Late-Disclosed Impeachment Evidence During Trial Is Not Brady “Suppression,” and Child-Witness Competency Turns on Mental Ability, Not Detailed Recall Introduction In Justin Scott Lake...

Boyer v. State: Malice Without Motive and Tightened Limits on Alternative-Suspect Hearsay Under W.R.E. 803(8)(C)

Date: Sep 13, 2025

Boyer v. State: Malice Without Motive and Tightened Limits on Alternative-Suspect Hearsay Under W.R.E. 803(8)(C) Introduction In Andrew Lee Boyer v. The State of Wyoming, 2025 WY 100 (Wyo. Sept. 12,...

Morris v. State (Wyo. 2025): Polygraph Results Offered to Bolster Credibility Fail Rule 702 and Cannot Establish Strickland Prejudice

Date: Sep 9, 2025

Polygraph Results Offered to Bolster Credibility Fail Rule 702 and Cannot Establish Strickland Prejudice Commentary on Randall Bruce Morris v. The State of Wyoming (2025 WY 98) Introduction In 2025...

The Jury Is the Lie Detector: Wyoming Supreme Court Rejects Polygraph-Based Ineffective Assistance Claim Under Rule 702 and Daubert

Date: Sep 9, 2025

The Jury Is the Lie Detector: Wyoming Supreme Court Rejects Polygraph-Based Ineffective Assistance Claim Under Rule 702 and Daubert Introduction In Randall Bruce Morris v. The State of Wyoming (2025...

Mere Noncompliance with a Custody Order Is Not a Material Change Absent Demonstrable Impact on the Child’s Welfare: Cornell v. Mecartney (2025 WY 97)

Date: Sep 9, 2025

Mere Noncompliance with a Custody Order Is Not a Material Change Absent Demonstrable Impact on the Child’s Welfare: Cornell v. Mecartney (2025 WY 97) Introduction In Kelly Cornell f/k/a Kelly Cornell...

“Any Amount Means Any Amount”: Wyoming Supreme Court Rejects a De Minimis Defense for Methamphetamine Possession under § 35‑7‑1031

Date: Sep 2, 2025

“Any Amount Means Any Amount”: Wyoming Supreme Court Rejects a De Minimis Defense for Methamphetamine Possession under § 35‑7‑1031 Case: David Wayne Gober v. The State of Wyoming, 2025 WY 96 (Wyo....

Imminent Danger Without Observable Impairment: Positive Methamphetamine UA and Ignoring Infant Car-Seat Instructions Suffice for Neglect in Wyoming

Date: Aug 31, 2025

Imminent Danger Without Observable Impairment: Positive Methamphetamine UA and Ignoring Infant Car-Seat Instructions Suffice for Neglect in Wyoming Introduction In In the Interest of MC, Minor Child:...

Cross-Border Equitable Contribution: Wyoming Endorses Florida’s 50/50 Presumption for Joint Mortgage Obligors – A Commentary on Katya Hutton v. Michael & J. Christopher Dykes (2025 WY 94)

Date: Aug 25, 2025

Cross-Border Equitable Contribution: Wyoming Endorses Florida’s 50/50 Presumption for Joint Mortgage Obligors Commentary on Katya Hutton v. Michael L. Dykes & J. Christopher Dykes, Co-PRs of the...

“The Boyer Confirmation” – Wyoming Re-Affirms that Dispatch-Derived License Information and a Single Observed Traffic Infraction Jointly Supply Reasonable Suspicion for a Stop

Date: Aug 19, 2025

“The Boyer Confirmation” – Wyoming Re-Affirms that Dispatch-Derived License Information and a Single Observed Traffic Infraction Jointly Supply Reasonable Suspicion for a Stop Introduction Andrew Lee...

Reserved Easements and the “Notice-to-Exercise” Rule: Commentary on Bruce H. Clark & Elaine Sullivan v. Bryce & Alisha Fuller, 2025 WY 92

Date: Aug 18, 2025

Reserved Easements and the “Notice-to-Exercise” Rule Supreme Court of Wyoming clarifies that a plat’s reservation clause does not ripen into an easement unless the grantor affirmatively notifies the...

Successor HOA Authority and the “Futility” Threshold for Pleading Amendments — A Comment on Dee Conger v. AVR Homeowner’s Association, Inc. (2025 WY 91)

Date: Aug 18, 2025

Successor HOA Authority and the “Futility” Threshold for Pleading Amendments — A Structured Commentary on Dee Conger, Trustee v. AVR Homeowner’s Association, Inc., 2025 WY 91 (Wyo. Sup. Ct. Aug. 13,...

“No Entity, No Title”: Wyoming Affirms That Estoppel-by-Deed Cannot Validate a Conveyance to a Non-Existent Corporation

Date: Aug 13, 2025

“No Entity, No Title”: Wyoming Affirms That Estoppel-by-Deed Cannot Validate a Conveyance to a Non-Existent Corporation Introduction In Kenneth R. Minshall v. Robin Griffin & Joy Osbon, 2025 WY 90,...

“Maturity Means Due”: The Wyoming Supreme Court’s Definitive Test for Shareholder Promissory Notes in Aristatek, Inc. v. Sheesley (2025 WY 89)

Date: Aug 13, 2025

“Maturity Means Due”: The Wyoming Supreme Court’s Definitive Test for Shareholder Promissory Notes Aristatek, Inc. v. Sheesley, 2025 WY 89 (Wyo. Aug. 6, 2025) 1. Introduction The consolidated appeal...

“Maturity-Date Rules Supreme”: Wyoming Clarifies that Fixed-Term Promissory Notes Are Payable at Expiration Without a Separate “On-Demand” Clause

Date: Aug 13, 2025

“Maturity-Date Rules Supreme”: Wyoming Clarifies that Fixed-Term Promissory Notes Are Payable at Expiration Without a Separate “On-Demand” Clause Introduction The consolidated appeal of Jeffry v....

When Maturity Means Payable: Wyoming Supreme Court Clarifies the Status of Shareholder Promissory Notes and Rejects Re-Characterisation as Capital Contributions

Date: Aug 13, 2025

When Maturity Means Payable: Wyoming Supreme Court Clarifies the Status of Shareholder Promissory Notes and Rejects Re-Characterisation as Capital Contributions 1. Introduction In Samuel Bruce King...