Wyoming Case Commentaries

Unjust Enrichment Survives the Statute of Frauds in Wyoming, but Requires Contemporaneous Notice of Expected Repayment

Date: May 24, 2026

Unjust Enrichment Survives the Statute of Frauds in Wyoming, but Requires Contemporaneous Notice of Expected Repayment 1. Introduction James Tallichet v. Jackson Hole Community Radio, Inc. (a/k/a...

Pinegar: Voir Dire Judicial-Misconduct Claims Require Actual Prejudice; Targeted Threats Can Satisfy § 6-2-505 “Reckless Disregard of Evacuation”

Date: May 22, 2026

Pinegar: Voir Dire Judicial-Misconduct Claims Require Actual Prejudice; Targeted Threats Can Satisfy § 6-2-505 “Reckless Disregard of Evacuation” 1. Introduction In Byron W. Pinegar, Jr., v. The...

Constitutional Challenge Alone Does Not Establish Irreparable Harm: Wyoming Requires a Personal and Particularized Injury for Preliminary Injunctions

Date: May 20, 2026

Constitutional Challenge Alone Does Not Establish Irreparable Harm: Wyoming Requires a Personal and Particularized Injury for Preliminary Injunctions Megan Degenfelder, In Her Official Capacity as...

Personal and Particularized Irreparable Harm Required to Preliminarily Enjoin a Statute (Even in Facial Constitutional Challenges)

Date: May 19, 2026

Personal and Particularized Irreparable Harm Required to Preliminarily Enjoin a Statute (Even in Facial Constitutional Challenges) Case: Megan Degenfelder, et al. v. Wyoming Education Association, et...

Summary Affirmance for Noncompliant Appellate Briefing and Inadequate Record—Including Pro Se Appeals from Arbitration Orders

Date: May 19, 2026

Summary Affirmance for Noncompliant Appellate Briefing and Inadequate Record—Including Pro Se Appeals from Arbitration Orders 1. Introduction Victorine O'Donoghue v. Jim Vito Construction, Inc., and...

Equitable Partition of Personal Property in Wyoming & District Court Jurisdiction over Partition Actions

Date: May 8, 2026

Equitable Partition of Personal Property in Wyoming & District Court Jurisdiction over Partition Actions I. Introduction In Richard Q. Navarro v. Antonio Oros-Garcia, 2026 WY 52, the Wyoming Supreme...

Unobjected Victim Impact Allegations of Uncharged Misconduct Are Not Plain Error Absent Proof of Inaccuracy and Sentencing Reliance (Atkinson v. State)

Date: May 7, 2026

Unobjected Victim Impact Allegations of Uncharged Misconduct Are Not Plain Error Absent Proof of Inaccuracy and Sentencing Reliance Introduction In Andrew Atkinson v. The State of Wyoming, 2026 WY 51...

Contractual Silence on Contingency-Fee Bonus Credit Is Not Ambiguity; Wage Claimant Must Prove an Agreed Bonus Rate

Date: May 5, 2026

Contractual Silence on Contingency-Fee Bonus Credit Is Not Ambiguity; Wage Claimant Must Prove an Agreed Bonus Rate Introduction In Dino Moncecchi v. Mckellar, Tiedeken & Scoggin, LLC, 2026 WY 50...

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming

Date: May 5, 2026

Protective-Order Violations and Repeated Surveillance Can Establish Specific Intent for Felony Stalking in Wyoming Introduction In Brent Douglas Gayman v. The State of Wyoming, 2026 WY 49, the...

Three-Year Suspension for Knowing Client Neglect and Failure to Comply with Disciplinary Probation

Date: Apr 30, 2026

Three-Year Suspension for Knowing Client Neglect and Failure to Comply with Disciplinary Probation Introduction In Board of Professional Responsibility, Wyoming State Bar v. Vaughn H. Neubauer, 2026...

Timely Permanency as the Decisive “Best Interests” Measure When Incarceration Delays Reunification

Date: Apr 24, 2026

Timely Permanency as the Decisive “Best Interests” Measure When Incarceration Delays Reunification 1. Introduction In the Interest Of: AG, minor child concerns whether a juvenile court may change a...

Wyoming Governmental Claims Act: Courts Must Cap Judgments at the Statutory Waiver Limit Absent Proven Excess Insurance, and County Hospitals Do Not Forfeit the Cap by Operating Statewide Commercially

Date: Apr 24, 2026

Wyoming Governmental Claims Act: Courts Must Cap Judgments at the Statutory Waiver Limit Absent Proven Excess Insurance, and County Hospitals Do Not Forfeit the Cap by Operating Statewide...

WGCA Rule: County Hospital Malpractice Judgments Must Be Capped at $1 Million Absent Excess Insurance

Date: Apr 24, 2026

WGCA Rule: County Hospital Malpractice Judgments Must Be Capped at $1 Million Absent Excess Insurance Introduction In Memorial Hospital of Converse County - Advanced Medicine, Hometown Care and...

Pro Se Custody Appeals Must Present Cogent Argument and Record Citations; Temporary Custody Disputes Become Moot After Final Modification

Date: Apr 23, 2026

Pro Se Custody Appeals Must Present Cogent Argument and Record Citations; Temporary Custody Disputes Become Moot After Final Modification 1. Introduction Nurian E. Duncan (Mother) appealed from a...

Motorized Vehicles Are Per Se “Deadly Weapons” Under Wyo. Stat. § 6-1-104(a)(iv); No “Serious Bodily Injury” Instruction Required

Date: Apr 22, 2026

Motorized Vehicles Are Per Se “Deadly Weapons” Under Wyo. Stat. § 6-1-104(a)(iv); No “Serious Bodily Injury” Instruction Required Case: Susanne Jacqueline Mayeux v. The State of Wyoming (2026 WY 43)...

Bad-Faith Use of a “First Right of Purchase” Can Constitute Tortious Interference; Tender at Closing Is Excused When Seller Cannot Perform; Attorney-Fee Punitive Damages Survive Due-Process Review

Date: Apr 17, 2026

Bad-Faith Use of a “First Right of Purchase” Can Constitute Tortious Interference; Tender at Closing Is Excused When Seller Cannot Perform; Attorney-Fee Punitive Damages Survive Due-Process Review...

Buyer’s Tender Is Excused When Seller Cannot Close; Bad-Faith Assertion of an Expired Right of First Purchase Can Be Tortious Interference; Fee-Based Punitive Damages Need Not Track a 1:1 Ratio

Date: Apr 17, 2026

Buyer’s Tender Is Excused When Seller Cannot Close; Bad-Faith Assertion of an Expired Right of First Purchase Can Be Tortious Interference; Fee-Based Punitive Damages Need Not Track a 1:1 Ratio 1....

Wyoming: Tender Excused and Tortious Interference Found Where an Expired Right of First Purchase Is Used to Obstruct Closing; Attorney-Fee Punitive Damages Upheld Without a 1:1 Ratio

Date: Apr 17, 2026

Wyoming: Tender Excused and Tortious Interference Found Where an Expired Right of First Purchase Is Used to Obstruct Closing; Attorney-Fee Punitive Damages Upheld Without a 1:1 Ratio Introduction In...

Bad-Faith Use of a First Right of Purchase Can Create Tort Liability and Excuse Tender; Attorney-Fee Punitive Damages Need Not Track a 1:1 Ratio

Date: Apr 17, 2026

Bad-Faith Use of a First Right of Purchase Can Create Tort Liability and Excuse Tender; Attorney-Fee Punitive Damages Need Not Track a 1:1 Ratio Case: Wyoming Fall Creek, LLC, a Wyoming Limited...

No Post-Docket “Clarification” Without Supreme Court Leave: Rule 60(a) Limits, Non-Recurring Business Distributions in Imputed Income, and Double-Counting Errors in Divorce Valuation

Date: Apr 17, 2026

No Post-Docket “Clarification” Without Supreme Court Leave: Rule 60(a) Limits, Non-Recurring Business Distributions in Imputed Income, and Double-Counting Errors in Divorce Valuation Introduction...