17 Wyoming opinions name it 1 courts 1982–2025 3 in the last five years
The cases below were cited by Wyoming courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
People v. Fremont Energy Corp.green2 sentences2021Id. [¶21] Under the exhaustion doctrine, “no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” Devon Energy, ¶ 32, 458 P.3d at 1210 (quoting People v. Fremont Energy Corp., 651 P.2d 802, 811 (Wyo. 1982)). 2020Regarding the exhaustion doctrine, we said “that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” 4 Id. at 811 (quoting Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41 , 50–51 (1938)). | 5 | 9 |
Glover v. Stategreen2 sentences2007Given the extensive and important administrative structure for handling review of tax assessments, we concluded the district court properly exercised its discretion in declining jurisdiction until the administrative remedies were exhausted. [152] As we said in Glover, 860 P.2d at 1171 , "the exhaustion doctrine applies where an agency alone has been granted or found to possess exclusive jurisdiction over the case." The purpose of the doctrine then is to avoid premature interruption of the administrative process where the agency has been created to apply a statute in the first *348 instance. 1996Wagoner fails to understand the doctrine of exhaustion. "`Exhaustion' applies where a claim is cognizable in the first instance by an administrative agency alone; judicial interference is withheld until the administrative process has run its course." Glover v. State, 860 P.2d 1169, 1171 (Wyo.1993) (quoting People v. Fremont Energy Corp., 651 P.2d 802, 810 (Wyo.1982)). | 2 | 4 |
Hirschfield v. Board of County Commissionersgreen2 sentences2007Hirschfield v. Board of County Com'rs, 944 P.2d 1139, 1142 (Wyo.1997). [¶15] The desire to avoid usurping the role of an administrative agency is manifested in two doctrines relied upon by the Department: the exhaustion requirement and the primary jurisdiction doctrine. 2004It is clear that, placed in its context, this passage simply reiterates our long-recognized rule that “[a]n action for declaratory judgment cannot be a substitute for an appeal from administrative 'decisions but is available even though there is a statutory method of appeal if it concerns the validity and construction of agency regulations, or if it concerns the constitutionality or interpretation of a statute upon which the administrative action is, or is to be based.” Hirschfield, 944 P.2d at 1142 (emphasis added); see also Ten Broek v. County of Washakie, 2003 WY 164, ¶ 8 , 82 P.3d 269, ¶8 | 2 | 2 |
Wyoming Department of Revenue v. Exxon Mobil Corp.green2 sentences2020Dep’t of Revenue v. Exxon Mobil Corp., 2007 WY 21, ¶ 15 , 150 P.3d 1216, 1222 (Wyo. 2007)). [¶32] This Court’s decision in People v. Fremont Energy Corp. also provides insight into how we treat the exhaustion doctrine. 2020Dep’t of Revenue v. Exxon Mobil Corp., 2007 WY 21, ¶ 15 , 150 P.3d 1216, 1222 (Wyo. 2007)). [¶32] This Court’s decision in People v. Fremont Energy Corp. also provides insight into how we treat the exhaustion doctrine. | 1 | 2 |
City of Cheyenne v. Simsgreen2 sentences1988The doctrine of exhaustion of administrative remedies was directly addressed by this court in People v. Fremont Energy Corp., Wyo., 651 P.2d 802 (1982) and City of Cheyenne v. Sims, Wyo., 521 P.2d 1347 (1974). “* * * The exhaustion doctrine applies where an agency alone has been granted or found to possess exclusive jurisdiction over the case. 1988The doctrine of exhaustion of administrative remedies was directly addressed by this court in People v. Fremont Energy Corp., Wyo., 651 P.2d 802 (1982) and City of Cheyenne v. Sims, Wyo., 521 P.2d 1347 (1974). "* * * The exhaustion doctrine applies where an agency alone has been granted or found to possess exclusive jurisdiction over the case. | 1 | 2 |
Snake River Brewing Co. v. Town of Jacksongreen2 sentences2004It is clear that, placed in its context, this passage simply reiterates our long-recognized rule that “[a]n action for declaratory judgment cannot be a substitute for an appeal from administrative 'decisions but is available even though there is a statutory method of appeal if it concerns the validity and construction of agency regulations, or if it concerns the constitutionality or interpretation of a statute upon which the administrative action is, or is to be based.” Hirschfield, 944 P.2d at 1142 (emphasis added); see also Ten Broek v. County of Washakie, 2003 WY 164, ¶ 8 , 82 P.3d 269, ¶8 2004It is clear that, placed in its context, this passage simply reiterates our long-recognized rule that “[a]n action for declaratory judgment cannot be a substitute for an appeal from administrative 'decisions but is available even though there is a statutory method of appeal if it concerns the validity and construction of agency regulations, or if it concerns the constitutionality or interpretation of a statute upon which the administrative action is, or is to be based.” Hirschfield, 944 P.2d at 1142 (emphasis added); see also Ten Broek v. County of Washakie, 2003 WY 164, ¶ 8 , 82 P.3d 269, ¶8 | 1 | 1 |
Broek v. County of Washakiegreen2 sentences2004It is clear that, placed in its context, this passage simply reiterates our long-recognized rule that “[a]n action for declaratory judgment cannot be a substitute for an appeal from administrative 'decisions but is available even though there is a statutory method of appeal if it concerns the validity and construction of agency regulations, or if it concerns the constitutionality or interpretation of a statute upon which the administrative action is, or is to be based.” Hirschfield, 944 P.2d at 1142 (emphasis added); see also Ten Broek v. County of Washakie, 2003 WY 164, ¶ 8 , 82 P.3d 269, ¶8 2004It is clear that, placed in its context, this passage simply reiterates our long-recognized rule that “[a]n action for declaratory judgment cannot be a substitute for an appeal from administrative 'decisions but is available even though there is a statutory method of appeal if it concerns the validity and construction of agency regulations, or if it concerns the constitutionality or interpretation of a statute upon which the administrative action is, or is to be based.” Hirschfield, 944 P.2d at 1142 (emphasis added); see also Ten Broek v. County of Washakie, 2003 WY 164, ¶ 8 , 82 P.3d 269, ¶8 | 1 | 1 |
Stephen Komninos v. Upper Saddle River Board Of Educationgreen1 sentence1996See Komninos By Komninos v. Upper Saddle River Board of Education, 13 F.3d 775, 778-79 (3d Cir.1994); see also New Mexico Association for Retarded Citizens v. New Mexico, 678 F.2d 847 (10th Cir.1982). | 1 | 1 |
New Mexico Association for Retarded Citizens v. The State of New Mexicogreen1 sentence1996See Komninos By Komninos v. Upper Saddle River Board of Education, 13 F.3d 775, 778-79 (3d Cir.1994); see also New Mexico Association for Retarded Citizens v. New Mexico, 678 F.2d 847 (10th Cir.1982). | 1 | 1 |
Association For Retarded Citizens Of Alabama, Inc. v. Wayne Teaguegreen1 sentence1996(Emphasis added.) The exhaustion requirement serves a number of important purposes which include: “(1) permitting the exercise of agency discretion and expertise on issues requiring these characteristics; (2) allowing the full development of technical issues and a factual record prior to court review; (3) preventing deliberate disregard and circumvention of agency procedures established by Congress; and (4) avoiding unnecessary judicial decisions by giving the agency the first opportunity to correct any error.” Hayes Through Hayes, 877 F.2d at 814 (quoting Association for Retarded Citizens, In | 1 | 1 |
Presbytery of Seattle v. King Countygreen2 sentences1996Presbytery of Seattle v. King County, 114 Wash.2d 320 , 787 P.2d 907, 916-17 (en banc), cert. denied, 498 U.S. 911 , 111 S.Ct. 284 , 112 L.Ed.2d 238 (1990) (footnote omitted). 1996Presbytery of Seattle v. King County, 114 Wash.2d 320 , 787 P.2d 907, 916-17 (en banc), cert. denied, 498 U.S. 911 , 111 S.Ct. 284 , 112 L.Ed.2d 238 (1990) (footnote omitted). | 1 | 1 |
McKart v. United Statesgreen2 sentences1982In City of Cheyenne v. Sims, Wyo., 521 P.2d 1347, 1349 (1974), this court adopted the view expressed by the United ■States Supreme Court in McKart v. United States, 395 U.S. 185, 193 , 89 S.Ct. 1657, 1662 , 23 L.Ed.2d 194, 203 (1969), under the doctrine of exhaustion of administrative remedies, “ ‘that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’ Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41 , 50-51, 58 S.Ct. 459,463 , 82 L.Ed. 638 (1938) * * The exhaustion doctrine applies where an agency alone h 1982In City of Cheyenne v. Sims, Wyo., 521 P.2d 1347, 1349 (1974), this court adopted the view expressed by the United ■States Supreme Court in McKart v. United States, 395 U.S. 185, 193 , 89 S.Ct. 1657, 1662 , 23 L.Ed.2d 194, 203 (1969), under the doctrine of exhaustion of administrative remedies, “ ‘that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’ Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41 , 50-51, 58 S.Ct. 459,463 , 82 L.Ed. 638 (1938) * * The exhaustion doctrine applies where an agency alone h | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Wyoming. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Devon Energy Production, Lp v. Grayson Mill Operating, Llc
green
2 sentences2021Id. [¶21] Under the exhaustion doctrine, “no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” Devon Energy, ¶ 32, 458 P.3d at 1210 (quoting People v. Fremont Energy Corp., 651 P.2d 802, 811 (Wyo. 1982)). 2021Stat. §15-5-112(b), this decision shall be certified to the City Manager for enforcement in accordance with law and with the City of Laramie FIRE DEPARTMENT CIVIL SERVICE RULES. [¶29] “The ‘purpose of the exhaustion doctrine is to avoid premature interruption of the administrative process where the agency has been created to apply a statute in the first place.’” Devon Energy, ¶ 31, 458 P.3d at 1210 (quoting Thomas Gilcrease Found., ¶ 12, 397 P.3d at 170 ). | 3 | 2021–2025 |
Jennifer P. Hanft, as Personal Representative of the Estate of Bret Lee Vance v. City of Laramie
green
2 sentences2025“Under the exhaustion doctrine, ‘no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’” Hanft, 2021 WY 52, ¶ 21 , 485 P.3d at 378 (quoting Devon Energy Prod. 2025“Under the exhaustion doctrine, ‘no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’” Hanft, 2021 WY 52, ¶ 21 , 485 P.3d at 378 (quoting Devon Energy Prod. | 2 | 2025–2025 |
Clare Sikora v. City of Rawlins
green
2 sentences2025The purpose of this doctrine is to “prevent[] judicial intrusion on the administrative process and allow[] the administrative entity with the 17 relevant expertise to engage in fact finding and any required application of discretion.” Sikora, 2017 WY 55, ¶ 14 , 394 P.3d at 476 . [¶46] The application of the exhaustion doctrine in this case presupposes that the Town Council created “an administrative process to govern zoning decisions.” Id. at ¶ 15, 394 P.3d at 476 . 2025The purpose of this doctrine is to “prevent[] judicial intrusion on the administrative process and allow[] the administrative entity with the 17 relevant expertise to engage in fact finding and any required application of discretion.” Sikora, 2017 WY 55, ¶ 14 , 394 P.3d at 476 . [¶46] The application of the exhaustion doctrine in this case presupposes that the Town Council created “an administrative process to govern zoning decisions.” Id. at ¶ 15, 394 P.3d at 476 . | 2 | 2025–2025 |
Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback One Charitable Trust Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback Two Charitable Trust and Thomas Gilcrease Foundation, as Trustee for the Gilcrease Hoback Three Charitable Trust v. Andy Cavallaro, sued in his Official Capacity as the Teton County Assessor, an Agency of the County of Teton, State of Wyoming
green
2 sentences2021Id. [¶21] Under the exhaustion doctrine, “no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” Devon Energy, ¶ 32, 458 P.3d at 1210 (quoting People v. Fremont Energy Corp., 651 P.2d 802, 811 (Wyo. 1982)). 2021Stat. §15-5-112(b), this decision shall be certified to the City Manager for enforcement in accordance with law and with the City of Laramie FIRE DEPARTMENT CIVIL SERVICE RULES. [¶29] “The ‘purpose of the exhaustion doctrine is to avoid premature interruption of the administrative process where the agency has been created to apply a statute in the first place.’” Devon Energy, ¶ 31, 458 P.3d at 1210 (quoting Thomas Gilcrease Found., ¶ 12, 397 P.3d at 170 ). | 2 | 2020–2021 |
Myers v. Bethlehem Shipbuilding Corp.
green
2 sentences2020Regarding the exhaustion doctrine, we said “that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” 4 Id. at 811 (quoting Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41 , 50–51 (1938)). 1982In City of Cheyenne v. Sims, Wyo., 521 P.2d 1347, 1349 (1974), this court adopted the view expressed by the United ■States Supreme Court in McKart v. United States, 395 U.S. 185, 193 , 89 S.Ct. 1657, 1662 , 23 L.Ed.2d 194, 203 (1969), under the doctrine of exhaustion of administrative remedies, “ ‘that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.’ Myers v. Bethlehem Shipbuilding Corp., 303 U.S. 41 , 50-51, 58 S.Ct. 459,463 , 82 L.Ed. 638 (1938) * * The exhaustion doctrine applies where an agency alone h | 2 | 1982–2020 |
Union Pacific Resources Co. v. State
green
1 sentence2007Union Pacific Resources Co., 839 P.2d at 864 . | 1 | 2007–2007 |
Hayes v. Unified School District No. 377
green
1 sentence1996(Emphasis added.) The exhaustion requirement serves a number of important purposes which include: “(1) permitting the exercise of agency discretion and expertise on issues requiring these characteristics; (2) allowing the full development of technical issues and a factual record prior to court review; (3) preventing deliberate disregard and circumvention of agency procedures established by Congress; and (4) avoiding unnecessary judicial decisions by giving the agency the first opportunity to correct any error.” Hayes Through Hayes, 877 F.2d at 814 (quoting Association for Retarded Citizens, In | 1 | 1996–1996 |
MCI Communications Corp. v. United States
green
1 sentence1996Presbytery of Seattle v. King County, 114 Wash.2d 320 , 787 P.2d 907, 916-17 (en banc), cert. denied, 498 U.S. 911 , 111 S.Ct. 284 , 112 L.Ed.2d 238 (1990) (footnote omitted). | 1 | 1996–1996 |
Presbytery of Seattle v. King County
green
2 sentences1996Presbytery of Seattle v. King County, 114 Wash.2d 320 , 787 P.2d 907, 916-17 (en banc), cert. denied, 498 U.S. 911 , 111 S.Ct. 284 , 112 L.Ed.2d 238 (1990) (footnote omitted). 1996Presbytery of Seattle v. King County, 114 Wash.2d 320 , 787 P.2d 907, 916-17 (en banc), cert. denied, 498 U.S. 911 , 111 S.Ct. 284 , 112 L.Ed.2d 238 (1990) (footnote omitted). | 1 | 1996–1996 |
Murray v. Carrier
green
1 sentence1988However, we think that the exhaustion doctrine, which is ‘principally designed to protect the state courts’ role in the enforcement of federal law and prevent disruption of state judicial proceedings,’ * * * generally requires that a claim of ineffective assistance be presented to the state courts as an independent claim before it may be used to establish cause for a procedural default.” 106 S.Ct. at 2645-2646 . | 1 | 1988–1988 |
Brown v. Allen
green
2 sentences1985In Brown v. Allen, 344 U.S. 443, 447 , 73 S.Ct. 397, 402 , 97 L.Ed. 469 (1953), it was held that the exhaustion doctrine does not foreclose federal habeas relief whenever a state remedy is available; once a prisoner has presented his claim to the highest state court on direct appeal and certiorari has been denied by the United States Supreme Court, he need not seek collateral relief from the state. 1985In Brown v. Allen, 344 U.S. 443, 447 , 73 S.Ct. 397, 402 , 97 L.Ed. 469 (1953), it was held that the exhaustion doctrine does not foreclose federal habeas relief whenever a state remedy is available; once a prisoner has presented his claim to the highest state court on direct appeal and certiorari has been denied by the United States Supreme Court, he need not seek collateral relief from the state. | 1 | 1985–1985 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.