Wyoming Case Commentaries

Binding Promissory Sentence Reductions Upon YOTP Completion

Date: Jun 3, 2025

Binding Promissory Sentence Reductions Upon YOTP Completion Introduction In David Ray Herrera, Jr. v. The State of Wyoming (2025 WY 62), the Wyoming Supreme Court addressed whether a district court’s...

Clarifying Trial Discretion and Warrant Particularity: Expert Witness Designation and Vehicle Search in Marquez v. Wyoming

Date: May 31, 2025

Clarifying Trial Discretion and Warrant Particularity: Expert Witness Designation and Vehicle Search in Marquez v. Wyoming Introduction This commentary examines the Supreme Court of Wyoming’s...

Clarification of Damages Certainty Requirement and Discretionary Attorney’s Fees in Breach of Contract Cases

Date: May 29, 2025

Clarification of Damages Certainty Requirement and Discretionary Attorney’s Fees in Breach of Contract Cases Introduction In Rick Holloway and John Hoskin v. Hidden Creek Outfitters, LLC and Park...

Defining “Necessity” for Private Roads and Implied Easements: Tilden v. Jackson

Date: May 24, 2025

Defining “Necessity” for Private Roads and Implied Easements: Tilden v. Jackson Introduction In Samuel J. Tilden v. Linda J. Jackson (2025 WY 57), the Supreme Court of Wyoming clarified critical...

Testerman v. Wyoming: Limits on Unnoticed 404(b) Evidence & Contextual Review of Vouching

Date: May 24, 2025

Testerman v. Wyoming: Limits on Unnoticed 404(b) Evidence & Contextual Review of Vouching Introduction Gabriel Lee Testerman v. State of Wyoming, 2025 WY 58, decided May 23, 2025 by the Wyoming...

Permissible Scope of Traffic Stops: Vehicle Registration Inquiry and Voluntary Consent

Date: May 23, 2025

Permissible Scope of Traffic Stops: Vehicle Registration Inquiry and Voluntary Consent Introduction Richard Clark Hanson v. The State of Wyoming (2025 WY 56) presented before the Supreme Court of...

Clarifying Attorney Duties in Real Estate Title Due Diligence and Client Communication Under W.R.P.C. 1.3 & 1.4(b)

Date: May 22, 2025

Clarifying Attorney Duties in Real Estate Title Due Diligence and Client Communication Under W.R.P.C. 1.3 & 1.4(b) Introduction This commentary examines the Supreme Court of Wyoming’s decision in...

Defining the Limitation Period for Legal Malpractice: Court Rejects Continuous Representation Rule in Groff v. Scoggin

Date: May 21, 2025

Defining the Limitation Period for Legal Malpractice: Court Rejects Continuous Representation Rule in Groff v. Scoggin Introduction Nichole M. Groff v. McKellar Tiedeken & Scoggin, LLC and Sean W....

Judicial Discretion in Parental Income Determination and the Limits of Rule 60 Relief in Child Support Modifications

Date: May 15, 2025

Judicial Discretion in Parental Income Determination and the Limits of Rule 60 Relief in Child Support Modifications Introduction David Martorano v. Melissa Mazzei f/k/a Melissa Martorano (2025 WY...

Establishing Self-Defense Jury Instruction Standards for Deadly Force in Vehicle Assaults

Date: May 9, 2025

Establishing Self-Defense Jury Instruction Standards for Deadly Force in Vehicle Assaults Introduction Bryant Ross Montoya v. State of Wyoming, 2025 WY 52 (May 8, 2025), is a Supreme Court of Wyoming...

Act, Error, or Omission Trigger in Professional Negligence: Substantial-Factor Approach Under Wyo. Stat. § 1-3-107

Date: May 2, 2025

Act, Error, or Omission Trigger in Professional Negligence: Substantial-Factor Approach Under Wyo. Stat. § 1-3-107 Introduction This commentary examines the certified-answer decision in Bankers...

Standards for Graduated Visitation Schedules in International Custody Modifications

Date: May 1, 2025

Standards for Graduated Visitation Schedules in International Custody Modifications Introduction Ekaterina Nicholaevna Pokrovskaya (“Mother”) and Eric Van Genderen Sr. (“Father”) were divorced in...

Partial Remission Standards in Bond Forfeiture: Gustke v. State of Wyoming

Date: Apr 25, 2025

Partial Remission Standards in Bond Forfeiture: In the Matter of the Bond Forfeiture of Karl Grant Gustke Introduction This commentary examines the Wyoming Supreme Court’s decision in John Gustke v....

Enforcement of Appellate Procedure Compliance for Pro Se Litigants: Hemmer v. City of Casper Police Department (2025 WY 49)

Date: Apr 25, 2025

Enforcement of Appellate Procedure Compliance for Pro Se Litigants: Hemmer v. City of Casper Police Department (2025 WY 49) Introduction In Hemmer v. City of Casper Police Department, 2025 WY 49, the...

Exemption of Temporary Use Permits on State Trust Lands from County Land-Use Regulations

Date: Apr 25, 2025

Exemption of Temporary Use Permits on State Trust Lands from County Land-Use Regulations Introduction In Teton County Board of County Commissioners v. State of Wyoming, Board of Land Commissioners...

Parental Duties Unaffected by Guardianship: Clarifying Support, Communication, and Judicial Estoppel under Wyo. Stat. §14-2-309(a)(i)

Date: Apr 24, 2025

Parental Duties Unaffected by Guardianship: Clarifying Support, Communication, and Judicial Estoppel under Wyo. Stat. §14-2-309(a)(i) Introduction This commentary examines Michael Session v. Michael...

Holliday v. Wyoming: Limits on Prosecutorial Vouching and Harmless Error in Identity Evidence

Date: Apr 22, 2025

Holliday v. Wyoming: Limits on Prosecutorial Vouching and Harmless Error in Identity Evidence Introduction William Corey Holliday v. The State of Wyoming, 2025 WY 44, is a Wyoming Supreme Court...

Bond Violations Triggering Cold Plea Provisions: Tirso Munguia v. State Clarifies Plea Agreement Enforcement

Date: Apr 10, 2025

Bond Violations Triggering Cold Plea Provisions: Tirso Munguia v. State Clarifies Plea Agreement Enforcement Introduction In Tirso Munguia v. The State of Wyoming (2025 WY 43), the Wyoming Supreme...

Equitable Discretion in Retroactive Child Support and Equity-Based Home Valuation: Lewis v. Lewis (2025 WY 42)

Date: Apr 10, 2025

Equitable Discretion in Retroactive Child Support and Equity-Based Home Valuation: Lewis v. Lewis (2025 WY 42) Introduction In the case of Laura Marie Lewis v. Ryan Ike Lewis (2025 WY 42), the...

Inventory Searches as Community Caretaker Function: Valid Warrantless Seizure of Arrestee’s Personal Property

Date: Apr 9, 2025

Inventory Searches as Community Caretaker Function: Valid Warrantless Seizure of Arrestee’s Personal Property Introduction The case of Brandon Christopher Serini v. The State of Wyoming (2025 WY 40)...