Wyoming Case Commentaries

“Knowingly” Re-defined: Fitzwater v. State of Wyoming and the Duty to Disclose Household Members & Joint Assets in Welfare Applications

Date: Aug 13, 2025

“Knowingly” Re-defined: Fitzwater v. State of Wyoming and the Duty to Disclose Household Members & Joint Assets in Welfare Applications Introduction Sarah Renee Fitzwater appealed her 18 felony...

Voluntary Dismissal No Longer a “Failure”: Wyoming Supreme Court Narrows the Savings Statute in Ellis v. Hiser (2025 WY 87)

Date: Aug 7, 2025

Voluntary Dismissal No Longer a “Failure”: Wyoming Supreme Court Narrows the Savings Statute in Ellis v. Hiser (2025 WY 87) Dianna Ellis, as Wrongful Death Representative for the Estate of Burke...

“The Oral-Presentation Cure” – Hill v. State of Wyoming (2025 WY 86) and the New Standard for Last-Minute Mitigating Evidence at Sentencing

Date: Jul 31, 2025

“The Oral-Presentation Cure” – Hill v. State of Wyoming (2025 WY 86) and the New Standard for Last-Minute Mitigating Evidence at Sentencing Introduction In Tyler James Hill v. The State of Wyoming,...

Clarifying the Limits of an Appellate Mandate: Wyoming Supreme Court Restricts Post-Judgment Revival of Un-pleaded Claims in Trust Litigation

Date: Jul 31, 2025

Clarifying the Limits of an Appellate Mandate: Wyoming Supreme Court Restricts Post-Judgment Revival of Un-pleaded Claims in Trust Litigation Introduction The decision in Redland v. Kimsey, 2025 WY...

Goetz Jurisdictional Rule: Wyoming Supreme Court Declares Rule 801 Sanctions for Attorney Tardiness to be Indirect Criminal Contempt Requiring Separate Proceedings

Date: Jul 31, 2025

Goetz Jurisdictional Rule: Wyoming Supreme Court Declares Rule 801 Sanctions for Attorney Tardiness to be Indirect Criminal Contempt Requiring Separate Proceedings 1. Introduction Case: In the Matter...

“From Fixed-Term to At-Will”: Wyoming Supreme Court Declares Post-Term Family Partnerships At-Will and Subject to Automatic Dissolution on Partner Withdrawal

Date: Jul 26, 2025

“From Fixed-Term to At-Will”: Wyoming Supreme Court Declares Post-Term Family Partnerships At-Will and Subject to Automatic Dissolution on Partner Withdrawal Introduction The Wyoming Supreme Court’s...

The Hanson Sufficiency Standard: Unobjected Hearsay and Circumstantial Evidence as Proof of “Without Authority” in Burglary & Theft Cases

Date: Jul 23, 2025

The Hanson Sufficiency Standard: Unobjected Hearsay and Circumstantial Evidence as Proof of “Without Authority” in Burglary & Theft Cases Introduction Andrew Michael Hanson appealed his burglary and...

“From Expectation to Discretion” – Gosselin v. State and the Non-Binding Nature of YOTP-Linked Sentence Reductions

Date: Jul 23, 2025

“From Expectation to Discretion” – Gosselin v. State and the Non-Binding Nature of YOTP-Linked Sentence Reductions 1. Introduction Logan Gregory Gosselin v. The State of Wyoming, 2025 WY 79, concerns...

“The Robin Sufficiency Standard” – Clarifying Unauthorized Control in Wyoming Vehicle-Theft Cases

Date: Jul 23, 2025

“The Robin Sufficiency Standard” – Clarifying Unauthorized Control in Wyoming Vehicle-Theft Cases Introduction In Michael Isreal Robin, Sr. v. State of Wyoming, 2025 WY 78, the Wyoming Supreme Court...

Beyond Formal Board Action: Agent-Authorization Liability in Wyoming Inverse Condemnation – A Commentary on Thomas Hamann v. Heart Mountain Irrigation District (2025 WY 75)

Date: Jul 13, 2025

Beyond Formal Board Action: Agent-Authorization Liability in Wyoming Inverse Condemnation A Comprehensive Commentary on Thomas Hamann v. Heart Mountain Irrigation District, 2025 WY 75 (Wyo. 2025) 1....

Wyoming Supreme Court Re-affirms the Limits of Mootness Exceptions in Juvenile Neglect Appeals

Date: Jul 13, 2025

Wyoming Supreme Court Re-affirms the Limits of Mootness Exceptions in Juvenile Neglect Appeals Introduction In In the Interest of: AB and JC, Minor Children; AC v. State of Wyoming, 2025 WY 74, the...

“Clay v. State” and the Clarification of Res Judicata’s Reach in Probation-Revocation Appeals

Date: Jul 6, 2025

“Clay v. State” and the Clarification of Res Judicata’s Reach in Probation-Revocation Appeals Introduction The Wyoming Supreme Court’s decision in Jeremy Gene Clay v. The State of Wyoming, 2025 WY...

The “Duke Rule” – When Victim Testimony & Expert Estimates Alone Sustain a Restitution Award

Date: Jul 6, 2025

The “Duke Rule” – When Victim Testimony & Expert Estimates Alone Sustain a Restitution Award Introduction In Timothy B. Duke v. State of Wyoming, 2025 WY 72, the Wyoming Supreme Court confronted a...

Gallegos v. Gallegos – Wyoming Supreme Court Re-Affirms Strict Procedural Compliance for Pro Se Appellants

Date: Jul 4, 2025

Gallegos v. Gallegos – Wyoming Supreme Court Re-Affirms Strict Procedural Compliance for Pro Se Appellants Introduction The Wyoming Supreme Court’s decision in Latoya L. Adams f/k/a Latoya L....

Sharpe v. Evans (2025 WY 70): Wyoming Supreme Court Reinforces the Limits on Collateral Attacks in Domestic Relations Appeals and Signals a Firm Stance Against Frivolous Litigation

Date: Jun 26, 2025

Sharpe v. Evans (2025 WY 70): Wyoming Supreme Court Reinforces the Limits on Collateral Attacks in Domestic Relations Appeals and Signals a Firm Stance Against Frivolous Litigation Introduction...

Liability-Caps as Waivers of Immunity, not Damage Limits – Commentary on Bain v. City of Cheyenne (2025 WY 67)

Date: Jun 20, 2025

Liability-Caps as Waivers of Immunity, not Damage Limits – Commentary on Bain v. City of Cheyenne, 2025 WY 67 Introduction On 18 June 2025 the Wyoming Supreme Court issued a significant decision in...

Bernard v. State: Wyoming Supreme Court Reinforces Res Judicata Limits on Rule 35(a) Motions and Requires Conformity Between Oral and Written Sentences

Date: Jun 18, 2025

Bernard v. State: Wyoming Supreme Court Reinforces Res Judicata Limits on Rule 35(a) Motions and Requires Conformity Between Oral and Written Sentences Introduction In David P. Bernard, Jr. v. State...

Wyoming Supreme Court Clarifies Finality & Voting Standards for Municipal Planning Decisions

Date: Jun 18, 2025

Wyoming Supreme Court Clarifies Finality & Voting Standards for Municipal Planning Decisions Introduction Case: Preserve Our Cody Neighborhoods et al. v. The Church of Jesus Christ of Latter-day...

Reinforcing the “Harm-Threshold”: Galvan v. Malone (2025) Clarifies Evidentiary Burden for Grandparent Visitation in Wyoming

Date: Jun 18, 2025

Reinforcing the “Harm-Threshold”: Salvador Galvan v. Sandra Malone, 2025 WY 65 1. Introduction This commentary analyzes the Wyoming Supreme Court’s recent decision in Galvan v. Malone, 2025 WY 65, a...

The “Mistake Exception” to Judicial Estoppel and the Elevated Hostility Test for Cotenants: A Commentary on Leeks Canyon Ranch, LLC v. Jackson Hole Hereford Ranch, LLC (2025 WY 63)

Date: Jun 11, 2025

The “Mistake Exception” to Judicial Estoppel and the Elevated Hostility Test for Cotenants: A Commentary on Leeks Canyon Ranch, LLC v. Jackson Hole Hereford Ranch, LLC (2025 WY 63) 1. Introduction In...