Wyoming Case Summaries
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Coverage since June 3, 2026

Wyoming

WyomingCriminalCriminal Procedureplea-agreements
Wyoming Supreme Court
Uncategorized

Hughes v. State — Plea Agreement “Sentencing Cap” Is a Non-Binding Recommendation, Not a Stipulated Sentence Under W.R.Cr.P. 11(e)(1)(C)

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The Wyoming Supreme Court unanimously affirmed consecutive sentences for a former Casper police officer who pleaded guilty to five counts of aggravated assault and battery following a prolonged armed standoff, holding that a plea agreement capping the State’s “sentencing argument” was a non-binding recommendation under W.R.Cr.P. 11(e)(1)(B)—not a stipulated sentence under 11(e)(1)(C)—and that Wyoming district courts need not make specific findings when deviating from a sentencing recommendation.

WyomingAppellate ProcedureEvidenceFamily Law
Wyoming Supreme Court
Uncategorized

In re AC and BI — Wyoming Supreme Court Affirms Neglect Finding, Upholds Admission of Post-Removal Hair Follicle Tests

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The Wyoming Supreme Court affirmed a juvenile court’s finding that Father neglected his two minor children, holding the court did not abuse its discretion in admitting hair follicle test results collected after the date of alleged neglect, because the tests covered the relevant period and any challenge to their probative force went to weight rather than admissibility.

WyomingCivil ProcedureCriminal
Wyoming Supreme Court
Uncategorized

Mostaert v. State — Wyoming Supreme Court Affirms Denial of Post-Conviction Motion to Return Seized Property

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The Wyoming Supreme Court affirmed a district court’s denial of a convicted shoplifter’s Rule 41(g) motion for return of seized property, holding that the State overcame the post-conviction presumption favoring return by presenting credible testimony that the items were likely stolen—and clarifying Wyoming’s burden-shifting framework for such motions for the first time in the context of alleged stolen property.

WyomingCivil ProcedureReal Estate
Wyoming Supreme Court
Uncategorized

Lewis v. Wolfe — Quiet Title Decree Naming “Husband and Wife” Creates Tenancy by Entirety Under Longstanding Wyoming Common Law

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The Wyoming Supreme Court affirmed dismissal of a daughter’s declaratory judgment action seeking to establish that her late father’s interest in real property passed to his estate rather than to her mother by survivorship. The court held that a 2012 quiet title decree identifying the parents as “Husband and Wife” created a tenancy by the entirety under longstanding Wyoming common law, and that the 2023 codification of that presumption in Wyoming Statute § 34-1-140(b) merely clarified — rather than changed — pre-existing law.

WyomingAppellate ProcedureCivil Procedure
Wyoming Supreme Court
Uncategorized

Moran v. Meadowlark Academy — Conservator Who Waited 190 Days to Answer Counterclaims Cannot Set Aside Default Without Articulating Rule 60(b) Grounds

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The Wyoming Supreme Court affirmed a default judgment entered against a conservator who waited 190 days to answer counterclaims and then failed to move to set aside the default with any citation to W.R.C.P. 55(c) or 60(b), failed to identify a Rule 60(b) justification, and failed to address the three-factor good cause test. A vague oral request to set aside default, unsupported by legal authority, does not satisfy the moving party’s burden.

WyomingBreach of ContractFamily Law
Wyoming Supreme Court
Uncategorized

Smerski v. Lemon — Wyoming Supreme Court Reverses Divorce Decree That Misread Postnuptial Agreement on Retirement Account Division

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The Wyoming Supreme Court reversed a divorce decree that treated all retirement accounts listed in postnuptial agreement exhibits as entirely separate property. The court held that the agreement’s express exclusion of retirement accounts from its “separate property” definition, combined with Paragraph 5(g)’s specific formula dividing pre- and post-June 2017 contributions, required the district court to apply the formula to the listed accounts as well.

WyomingConstitutionalCriminal
Wyoming Supreme Court
Uncategorized

Manders v. State — Castle Doctrine Presumptions Do Not Extend to Driveway or Yard; Self-Defense Immunity Denied Where Victim Was Never Entering the Home

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The Wyoming Supreme Court affirmed the denial of self-defense immunity to a man who shot and killed his neighbor during a dispute over property boundaries, holding that Wyoming’s castle doctrine presumptions under § 6-2-602(b) and (d) do not extend to outdoor areas such as driveways, and that a defendant’s subjective belief that an intruder was about to enter his home — without objective corroboration — is insufficient to trigger the statutory presumptions.

WyomingCivil ProcedureFamily Law
Wyoming Supreme Court
Uncategorized

Causey v. Causey — Post-Majority Support Denied Where Physically Disabled Adult Child Earns SSDI and Plans College Despite Ongoing Medical Needs

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The Wyoming Supreme Court affirmed the district court’s denial of post-majority parental support for a physically disabled adult child. Although Son was found to be physically disabled, the court held the evidence supported the finding that he was capable of self-support where he received SSDI, performed daily living activities independently, and planned to pursue college on a merit scholarship.

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