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  • Commentaries
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Wyoming Case Commentaries

Silence Is Not Ambiguity: Wyoming High Court Holds Written Judgment Cannot Supply a Probation Length Omitted at Sentencing

Silence Is Not Ambiguity: Wyoming High Court Holds Written Judgment Cannot Supply a Probation Length Omitted at Sentencing

Date: Nov 7, 2025
Silence Is Not Ambiguity: Wyoming High Court Holds Written Judgment Cannot Supply a Probation Length Omitted at Sentencing Introduction In James D. Van Winter v. State of Wyoming, 2025 WY 119 (Wyo....
Silence Is Conflict: Wyoming Supreme Court Requires Probation Length Be Orally Pronounced; Written Judgment Cannot Supply Missing Term

Silence Is Conflict: Wyoming Supreme Court Requires Probation Length Be Orally Pronounced; Written Judgment Cannot Supply Missing Term

Date: Nov 7, 2025
Silence Is Conflict: Wyoming Supreme Court Requires Probation Length Be Orally Pronounced; Written Judgment Cannot Supply Missing Term Introduction In James D. Van Winter v. The State of Wyoming,...
Robin v. State: Wyoming Affirms 911 Calls Made During an Ongoing Emergency Are Nontestimonial and Admissible as Excited Utterances

Robin v. State: Wyoming Affirms 911 Calls Made During an Ongoing Emergency Are Nontestimonial and Admissible as Excited Utterances

Date: Nov 5, 2025
Robin v. State: Wyoming Affirms 911 Calls Made During an Ongoing Emergency Are Nontestimonial and Admissible as Excited Utterances Introduction In Michael Isreal Robin, Sr. v. State of Wyoming, 2025...
Intent to Steal May Be Inferred from Social Media Planning and Forced Entry; Co‑Conspirator Messages Admissible with Independent Proof of Conspiracy

Intent to Steal May Be Inferred from Social Media Planning and Forced Entry; Co‑Conspirator Messages Admissible with Independent Proof of Conspiracy

Date: Oct 30, 2025
Intent to Steal May Be Inferred from Social Media Planning and Forced Entry; Co‑Conspirator Messages Admissible with Independent Proof of Conspiracy Introduction This commentary examines the Wyoming...
Uniform “Reasonable Probability” Harmless‑Error Standard Adopted; Defendant’s Absence from Suppression Hearing Deemed Harmless; Confession Upheld as Voluntary

Uniform “Reasonable Probability” Harmless‑Error Standard Adopted; Defendant’s Absence from Suppression Hearing Deemed Harmless; Confession Upheld as Voluntary

Date: Oct 24, 2025
Uniform “Reasonable Probability” Harmless‑Error Standard Adopted; Defendant’s Absence from Suppression Hearing Deemed Harmless; Confession Upheld as Voluntary Introduction In Cheri Lynn Marler v....
“Dispositive Must Mean Case-Ending”: Wyoming Supreme Court Invalidates Non‑Dispositive Conditional Plea Under W.R.Cr.P. 11(a)(2) in Kotrc v. State

“Dispositive Must Mean Case-Ending”: Wyoming Supreme Court Invalidates Non‑Dispositive Conditional Plea Under W.R.Cr.P. 11(a)(2) in Kotrc v. State

Date: Oct 24, 2025
“Dispositive Must Mean Case-Ending”: Wyoming Supreme Court Invalidates Non‑Dispositive Conditional Plea Under W.R.Cr.P. 11(a)(2) in Kotrc v. State Introduction In Cody Allan Kotrc v. State of...
A Bifurcated Test for “Cruel or Unusual”: Wyoming Supreme Court Clarifies Article 1, § 14 and Declines Categorical Protections for Emerging Adults

A Bifurcated Test for “Cruel or Unusual”: Wyoming Supreme Court Clarifies Article 1, § 14 and Declines Categorical Protections for Emerging Adults

Date: Oct 22, 2025
A Bifurcated Test for “Cruel or Unusual”: Wyoming Supreme Court Clarifies Article 1, § 14 and Declines Categorical Protections for Emerging Adults Introduction In Christopher Robert Hicks v. The...
Consciousness-of-Guilt and Intent: Wyoming High Court Affirms Admissibility of “Going Back to Prison” Statements Under W.R.E. 404(b) in Felony Stalking

Consciousness-of-Guilt and Intent: Wyoming High Court Affirms Admissibility of “Going Back to Prison” Statements Under W.R.E. 404(b) in Felony Stalking

Date: Oct 13, 2025
Consciousness-of-Guilt and Intent: Wyoming High Court Affirms Admissibility of “Going Back to Prison” Statements Under W.R.E. 404(b) in Felony Stalking Case: Jason Scott Bragdon v. The State of...
“Convicted Felon” Accusations Are Defamation Per Se; Party‑Opponent Statements in Affidavits Can Defeat Summary Judgment — Lewis v. Jolley (Wyo. 2025)

“Convicted Felon” Accusations Are Defamation Per Se; Party‑Opponent Statements in Affidavits Can Defeat Summary Judgment — Lewis v. Jolley (Wyo. 2025)

Date: Oct 10, 2025
“Convicted Felon” Accusations Are Defamation Per Se; Party‑Opponent Statements in Affidavits Can Defeat Summary Judgment — Lewis v. Jolley (Wyo. 2025) Introduction In Brian C. Lewis v. Rebecca Lyn...
Invited Error Waives Instructional Objections; Single-Count Third-Degree Sexual Abuse Requires No Act-Specific Jury Instruction

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)

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)

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)

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)

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

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)

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

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

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)

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

“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....
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