VictimsGuide • Wyoming Law & Case Authorities
Wyoming Case Authority Library
A research index of Wyoming statutes and judicial decisions governing automobile insurance, crash liability, UM/UIM coverage, claims handling, policy interpretation, insured status, settlement, damages and related recovery issues.
How This Library Classifies Authority
Principal Wyoming Doctrinal Chains
Coverage Disclosure
Darlow → Shrader → Cathcart → BergantinoFirst-Party Bad Faith
McCullough → Darlow → Hatch → Shirley → MatlackUM/UIM & Stacking
Ramsour → Stamper → Aaron → BergantinoMandatory Coverage / Exclusions
Allstate → Martin → PribbleAgent / Procurement Duties
Hursh → Arrow → Feather → Gordon → BroderickThird-Party Failure to Settle
Fowler → Herrig → Jarvis → GAINSCOCrash Liability
Oberson → Roberts → Cardenas → BunningDuty to Defend
Aetna → First Wyoming Bank → Shoshone First Bank → MatlackCurrent Statutory Framework
Search the Case Authority Index
McCullough v. Golden Rule Insurance Co.
1990 WY 35, 789 P.2d 855Foundational Wyoming first-party bad-faith case. Establishes the absence-of-reasonable-basis plus knowledge/reckless-disregard framework and the objective fairly-debatable standard.
Darlow v. Farmers Insurance Exchange
1991 WY 157, 822 P.2d 820Auto/MedPay authority applying first-party bad-faith principles and recognizing circumstances in which an insurer must inform its insured about available policy coverage.
State Farm v. Shrader
1994 WY 89, 882 P.2d 813Major UM authority permitting direct action against the UM carrier and forming part of Wyoming's coverage-disclosure and first-party good-faith line.
Cathcart v. State Farm
2005 WY 154, 123 P.3d 579Principal first-party UM coverage-disclosure case. Emphasizes the insurer's duty to inform its insured of the extent of available coverage before settlement, particularly when the insured lacks that knowledge.
Bergantino v. State Farm
2021 WY 138, 500 P.3d 249Modern UIM authority enforcing the policy's definition of underinsured vehicle while reaffirming Wyoming's insurance-contract and coverage-information principles.
Broderick v. Dairyland Insurance Co.
2012 WY 22, 270 P.3d 684Confirms Wyoming does not statutorily mandate UIM and warns that requesting “full coverage” does not create insurance absent from the written policy.
Aaron v. State Farm
2001 WY 112, 34 P.3d 929Principal Wyoming multiple-policy UIM stacking case. Requires clear limitations on aggregation and rejects repeated credit for a single tortfeasor payment.
Ramsour v. Grange Insurance Association
541 P.2d 35 (Wyo. 1975)Foundational inter-policy UM stacking authority. Separate coverage may contribute toward actual uncompensated damages but cannot produce recovery above the actual loss.
Commercial Union Insurance Co. v. Stamper
732 P.2d 534 (Wyo. 1987)Principal intra-policy stacking case. Enforces clear language limiting recovery despite several covered vehicles under one policy.
State ex rel. Farmers v. District Court
1993 WY 4, 844 P.2d 1099UIM authority involving policy treatment where tortfeasor liability limits and UIM limits were equal.
Eklund v. Farmers Insurance Exchange
2004 WY 24, 86 P.3d 259UIM carrier that preserved its rights and did not participate in the tort settlement was not automatically bound by stipulated damages.
Ulrich v. USAA
839 P.2d 942 (Wyo. 1992)Addresses the causal nexus required for UM coverage arising out of ownership, maintenance, or use of a vehicle.
Hatch v. State Farm
1992 WY 172, 842 P.2d 1089Investigation matters to the fairly-debatable inquiry. An insurer cannot avoid scrutiny by failing to develop or recklessly ignoring facts necessary to evaluate the claim.
Farmers Insurance Exchange v. Shirley
1998 WY 63, 958 P.2d 1040MedPay and delay authority addressing bad-faith damages, emotional injury, and the higher showing required for punitive damages.
Matlack v. Mountain West Farm Bureau
2002 WY 60, 44 P.3d 73Important bad-faith and duty-to-defend authority addressing potentially covered allegations and Wyoming's insurance standards.
Doctors' Co. v. Insurance Corp. of America
1993 WY 151, 864 P.2d 1018Foundational Wyoming policy-interpretation authority: plain meaning, policy as a whole, ambiguity against the insurer, but no manufactured ambiguity.
Allstate Insurance Co. v. Wyoming Insurance Department
672 P.2d 810 (Wyo. 1983)Compulsory-insurance authority preventing household exclusions from eliminating Wyoming's statutory minimum liability protection.
Martin v. Farmers Insurance Exchange
1995 WY 64, 894 P.2d 618Enforces clear household exclusion above Wyoming's statutory minimum while preserving the compulsory-insurance floor.
Pribble v. State Farm
1997 WY 32, 933 P.2d 1108Reaffirms enforceability of clear household exclusions above the mandatory minimum and limits reasonable-expectations arguments where policy language is unambiguous.
Century Surety Co. v. Jim Hipner, LLC
2016 WY 81, 377 P.3d 784Adopts Wyoming's notice-prejudice rule and demonstrates that public policy can override clear policy language purporting to eliminate coverage solely for late notice.
Hursh Agency, Inc. v. Wigwam Homes, Inc.
664 P.2d 27 (Wyo. 1983)Foundational failure-to-procure authority requiring reasonable skill, care, and diligence when an agent undertakes to obtain specified insurance.
Gordon v. Spectrum, Inc.
1999 WY 75, 981 P.2d 488Ordinary insurance agents have no universal continuing duty to discover every coverage gap; a special relationship may alter the analysis.
Feather v. State Farm
1994 WY 48, 872 P.2d 1177Automobile authority applying the duty to read insurance documents and addressing newly acquired vehicle coverage.
Mendenhall v. Mountain West
2012 WY 46, 274 P.3d 407Certificate of title is important but not necessarily conclusive proof of actual vehicle ownership for coverage analysis.
Phoenix Assurance Co. v. Latta
373 P.2d 146 (Wyo. 1962)Implied permission may arise from course of conduct and surrounding circumstances.
Wyoming Farm Bureau v. May
434 P.2d 507 (Wyo. 1967)Express restrictions on permission can prevent a first permittee from extending insured use to a second driver.
Jack v. Enterprise Rent-A-Car
1995 WY 125, 899 P.2d 891Rejects automatic rental-owner liability while recognizing that independent negligent-entrustment theories require their own proof.
Shafer v. TNT Well Service, Inc.
2012 WY 126, 285 P.3d 958Treats negligent entrustment as an independent theory rather than merely another label for respondeat superior.
Oberson v. Shreeve
1983 WY 129, 672 P.2d 1294Comparative-fault authority demonstrating that a traffic violation does not eliminate comparative analysis of the conduct of all drivers.
Roberts v. Estate of Randall
2002 WY 115, 51 P.3d 204Treats sudden emergency as a circumstance within ordinary reasonable-care analysis; the driver cannot negligently create the emergency relied upon.
Cardenas v. Fossen
2024 WY 117Collision or loss of control does not itself compel a negligence finding when the circumstances permit more than one reasonable inference.
Bunning v. Romero
2026 WY 40Current motor-vehicle comparative-fault authority. A preferred driver with the right of way still owes reasonable care, and speeding or unsafe driving can support fault allocation.
Banks v. Crowner
1985 WY 10, 694 P.2d 101Supports recovery of the reasonable value of necessary medical services even where the services were furnished gratuitously.
Rudy v. Bossard
2000 WY 30, 997 P.2d 480Future medical damages may be submitted when the substance of the evidence establishes that future care is more likely than not.
Union Pacific Railroad v. Richards
1985 WY 82, 702 P.2d 1272Distinguishes impairment of future earning capacity from actual wages already lost.
Weaver v. Mitchell
1986 WY 72, 715 P.2d 1361Recognizes spousal loss of consortium and its derivative relationship to the injured spouse's comparative fault.
Kendrick v. Barker
2001 WY 2, 15 P.3d 734Principal settlement-finality warning. A negotiated personal-injury settlement may remain enforceable despite later discovery of a more serious injury.
Haderlie v. Sondgeroth
1993 WY 155, 866 P.2d 703Modern post-joint-liability settlement authority rejecting an automatic dollar-for-dollar credit where settled actors were assigned no fault.
Stilson v. Hodges
1997 WY 35, 934 P.2d 736Automobile subrogation and assignment authority involving medical payments and an insurer's asserted interest in tort recovery.
Knowles v. Corkill
2002 WY 119, 51 P.3d 859Principal wrongful-death damages authority distinguishing loss of probable future companionship, society and comfort from nonrecoverable grief or mental anguish as separate damage categories.
Farmers Insurance Exchange v. Dahlheimer
2000 WY 74, 3 P.3d 820Multiple wrongful-death beneficiaries did not multiply the UM per-person limit where only the decedent sustained bodily injury.
Hamlin v. Transcon Lines
1985 WY 74, 701 P.2d 1139Foundational governmental motor-vehicle waiver authority under the Wyoming Governmental Claims Act.
DeWald v. State
1986 WY 120, 719 P.2d 643Police-pursuit authority demonstrating that waiver of immunity does not eliminate the need to prove negligence and proximate causation.
Bain v. City of Cheyenne
2025 WY 67, 570 P.3d 725Modern authority upholding the Governmental Claims Act's individual liability limitation as a boundary on Wyoming's waiver of sovereign immunity.
Aetna Insurance Co. v. Lythgoe
618 P.2d 1057 (Wyo. 1980)Foundational Wyoming rule that the duty to defend is broader than the ultimate duty to indemnify.
First Wyoming Bank v. Continental Insurance Co.
1993 WY 126, 860 P.2d 1094Final rehearing opinion. Compares underlying allegations to policy coverage and confirms that pleading labels do not manufacture a covered occurrence.
Shoshone First Bank v. Pacific Employers
2000 WY 126, 2 P.3d 510One potentially covered claim can require defense of the entire action; a reservation letter cannot unilaterally create a defense-cost reimbursement right absent policy support.
Western Casualty & Surety Co. v. Fowler
390 P.2d 602 (Wyo. 1964)Foundational third-party failure-to-settle authority requiring intelligent, honest judgment and appropriate consideration of the insured's personal exposure.
Herrig v. Herrig
1992 WY 185, 844 P.2d 487Insurer's good-faith duty runs to its insured, not the adverse claimant; Wyoming's unfair-claims statute does not create an implied private third-party action.
Jarvis v. Farmers Insurance Exchange
1997 WY 131, 948 P.2d 898Declines to extend Wyoming's traditional failure-to-settle tort where the insured never became subject to a qualifying excess judgment.
GAINSCO Insurance Co. v. Amoco Production Co.
2002 WY 122, 53 P.3d 1051Major failure-to-settle authority addressing objective settlement evaluation, assignment of insured rights, excess judgments and covenants not to execute.
Federal Cases Applying Wyoming Law
Historical & QC Cautions
- Use Haderlie rather than pre-1986 contribution cases for the modern settlement-credit structure.
- Use the final rehearing opinion in First Wyoming Bank, 1993 WY 126, rather than the superseded earlier opinion.
- Ragsdale v. Hartford is procedural: the appeal was dismissed as untimely and is not a merits holding on the disputed subrogation issue.
- Federal cases such as Dyer and Curtis must be labeled federal authority applying Wyoming law.
- Do not treat absence of a case in this library as proof that no Wyoming authority exists.