Wyoming Supreme Court, 1993

The court affirmed summary judgment determining that the former insurer had no coverage because no claim, as defined by its claims-made policy, was made against the physician before that policy expired.

The court held that the employment covenant was supported by separate consideration supplied by a later pay increase and that its restriction on small-animal practice within five miles of Laramie was reasonable.

The Wyoming Supreme Court held that the trial court abused its discretion by refusing to modify or terminate the alimony provision of a Florida divorce decree because the husband demonstrated a material and substantial change in circumstances.

The Wyoming Supreme Court held that an application for a default judgment under Rule 55(b) need not be made in a formal written document. It reversed the order setting aside the default and default judgment because the defendants showed no qualifying basis for relief under Rule 60(b) and no good cause under Rule…

The court affirmed Saldana’s conviction, holding that the telephone records were obtained without a constitutionally protected search and were not intercepted under Wyoming’s communications statute.

The Wyoming Supreme Court held that the state’s comparative negligence statute does not bar recovery in a legal‑malpractice action based on breach of contract and breach of fiduciary duty, and it does not require the plaintiff’s recovery to be reduced by his percentage of fault.