Rick Wilder, Appellant (plaintiff) v. Cody Country Chamber of Commerce, a Wyoming Non-Profit Corporation, Appellee…

Summary

The court affirmed summary judgment for the Chamber on the implied-covenant, negligence, defamation, and intentional-interference claims, but reversed summary judgment on breach of contract and intentional infliction of emotional distress. It held that factual disputes concerned the parties’ oral employment agreement and the meaning and consideration of a later memorandum, and that the alleged conduct could support a jury finding of outrageousness. The court also held that the trial court abused its discretion by denying leave to amend without considering the proposed additional claims, and that objections to an appellate affidavit were waived while the Chamber’s notice of additional authority was untimely. Chief Justice Macy, dissenting in part, would also have reversed on defamation; Justice Golden, concurring in part and dissenting in part, would have affirmed on breach of contract, the implied covenant, and outrageous conduct.