default hearing (Wyoming) · Go Syfert
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default hearing in Wyoming

8 Wyoming opinions name it 1 courts 2002–2025 4 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.

Followed or applied (8)

CaseFollowedCited
Noonan v. Noonangreen
wyo · 2005 · cited in 2 Wyoming opinions naming this issue, 2013–2022
2 sentences

2022Noonan, ¶ 8, 122 P.3d at 966 (reversing because “[t]hat did not happen in this case”). 6 [¶31] In Brush v. Davis, 2013 WY 161 , 315 P.3d 648 (Wyo. 2013), the district court did precisely what Noonan contemplates in a default situation where both parties attend the default hearing.

2013Noonan, ¶ 8, 122 P.3d at 966 , recognized that it may be difficult to obtain the statutory financial affidavit from a defaulting party, but directed the district court to "obtain sufficient financial evidence of both parties' income to make factual determinations, and to comply with the presumptive child support guidelines." In this case, Mother appeared at the default hearing and the district court ordered her to submit a financial affidavit, which she did not do.

12
Kelly Suzanne Brush, F/K/A Kelly Suzanne Davis v. Roger Ryan Davisgreen
wyo · 2013 · cited in 2 Wyoming opinions naming this issue, 2021–2022
2 sentences

2022Noonan, ¶ 8, 122 P.3d at 966 (reversing because “[t]hat did not happen in this case”). 6 [¶31] In Brush v. Davis, 2013 WY 161 , 315 P.3d 648 (Wyo. 2013), the district court did precisely what Noonan contemplates in a default situation where both parties attend the default hearing.

2022Noonan, ¶ 8, 122 P.3d at 966 (reversing because “[t]hat did not happen in this case”). 6 [¶31] In Brush v. Davis, 2013 WY 161 , 315 P.3d 648 (Wyo. 2013), the district court did precisely what Noonan contemplates in a default situation where both parties attend the default hearing.

12
Gehnert v. Stategreen
· 2018 · cited in 1 Wyoming opinions naming this issue, 2025–2025
1 sentence

2025State Bar v. Crawford-Fink, 2018 WY 130 , ¶ 24, 430 P.3d 323, 332 (Wyo. 2018) (finding an attorney violated Rule 1.3 by failing to obtain complete information about the parties’ assets and liabilities prior to the default hearing, failing to meet with her client to discuss what information would be required for the hearing so the client could obtain that information, preparing a decree that contained erroneous information, and failing to act with reasonable diligence to correct those errors and get the matter concluded); Hinckley, 2022 WY 18 , ¶¶ 25–26, 80, 503 P.3d at 599, 613 (finding a pros

11
Rocio Esmeralda Mercado Soto Linch v. Ronald B. Linchgreen
wyo · 2015 · cited in 1 Wyoming opinions naming this issue, 2021–2021
2 sentences

2021Id., ¶¶ 16, 30-35, 361 P.3d at 313, 316-17 . [¶26] We concluded the district court should have held a default hearing, but the error did not render the judgment void.

2021Id., ¶ 34, 361 P.3d at 317 (quoting Spitzer, 777 P.2d at 593 ). [¶27] The salient holding of Linch is the district court cannot enter a form of judgment provided by the non-defaulting party in a divorce action without holding a default hearing to determine the proper relief.

11
Multiple Resort Ownership Plan, Inc. v. Design-Build-Manage, Inc.green
wyo · 2002 · cited in 1 Wyoming opinions naming this issue, 2020–2020
1 sentence

2020See Multiple Resort Ownership Plan, ¶ 24, 45 P.3d at 655 (“The burden, however, is upon those seeking more than mere nominal damages to prove their damages.”).

11
Rosty v. Skajgreen
wyo · 2012 · cited in 1 Wyoming opinions naming this issue, 2016–2016
2 sentences

2016“Whether a trial court violated a litigant’s right to due process presents a question of law that we.review de novo.” Rosty v. Skaj, 2012 WY 28, ¶ 16 , 272 P.3d 947, 953 (Wyo. 2012).

2016“Whether a trial court violated a litigant’s right to due process presents a question of law that we.review de novo.” Rosty v. Skaj, 2012 WY 28, ¶ 16 , 272 P.3d 947, 953 (Wyo. 2012).

11
Angus Hunt Ranch, Inc. v. Reb, Inc.green
wyo · 1978 · cited in 1 Wyoming opinions naming this issue, 2002–2002
1 sentence

2002See also Angus Hunt Ranch, Inc. v. REB, Inc 577 P.2d 645, 650 (Wyo.1978). [¶ 9] The Contract provided, in applicable part: 27.

11
Amoco Production Co. v. Stauffer Chemical Co.green
wyo · 1980 · cited in 1 Wyoming opinions naming this issue, 2002–2002
1 sentence

2002Co. v. Stauffer Chemical Co., 612 P.2d 463, 465 (Wyo.1980) and cases cited therein) our appellate obligation in cases of this sort is to interpret and construe the contract as a matter of law in order to shed light on the intention and understanding of the parties.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Wyoming. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Board of Professional Responsibility, Wyoming State Bar v. Becket Benedict Hinckley, Wsb 6-3434 green
wyo · 2022
1 sentence

2025State Bar v. Crawford-Fink, 2018 WY 130 , ¶ 24, 430 P.3d 323, 332 (Wyo. 2018) (finding an attorney violated Rule 1.3 by failing to obtain complete information about the parties’ assets and liabilities prior to the default hearing, failing to meet with her client to discuss what information would be required for the hearing so the client could obtain that information, preparing a decree that contained erroneous information, and failing to act with reasonable diligence to correct those errors and get the matter concluded); Hinckley, 2022 WY 18 , ¶¶ 25–26, 80, 503 P.3d at 599, 613 (finding a pros

12025–2025
In the Matter of the Termination of Parental Rights to: NRL, EL and EYL, Minor Children, EL green
wyo · 2015
2 sentences

2023In re NRL, 2015 WY 27, ¶ 1 , 344 P.3d at 759 .

2023In re NRL, 2015 WY 27, ¶ 1 , 344 P.3d at 759 .

12023–2023
Spitzer v. Spitzer green
wyo · 1989
1 sentence

2021Id., ¶ 34, 361 P.3d at 317 (quoting Spitzer, 777 P.2d at 593 ). [¶27] The salient holding of Linch is the district court cannot enter a form of judgment provided by the non-defaulting party in a divorce action without holding a default hearing to determine the proper relief.

12021–2021
In the Matter of the Termination of Parental Rights To HLL and KGS, Minor Children: CLB v. State of Wyoming, Department of Family Services green
wyo · 2016
1 sentence

2021Id., ¶ 14 n.3, 276 P.3d at 396 n.3. [¶31] In In re HLL, ¶¶ 25, 27-28, 372 P.3d at 190-91 , we stated “with the appropriate notice, default can be entered against a non-appearing parent” in a termination action, but the State is still required to present clear and convincing evidence of a basis for termination under § 14-2-309(a) at the default hearing.

12021–2021
In Re Zmets green
wyo · 2012
2 sentences

2021Id., ¶ 14 n.3, 276 P.3d at 396 n.3. [¶31] In In re HLL, ¶¶ 25, 27-28, 372 P.3d at 190-91 , we stated “with the appropriate notice, default can be entered against a non-appearing parent” in a termination action, but the State is still required to present clear and convincing evidence of a basis for termination under § 14-2-309(a) at the default hearing.

2021Id., ¶ 14 n.3, 276 P.3d at 396 n.3. [¶31] In In re HLL, ¶¶ 25, 27-28, 372 P.3d at 190-91 , we stated “with the appropriate notice, default can be entered against a non-appearing parent” in a termination action, but the State is still required to present clear and convincing evidence of a basis for termination under § 14-2-309(a) at the default hearing.

12021–2021

Statutes the citing opinions construe

WY § Wyo. Stat. § 20-2-307 (3)

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.

Where else courts name it

CA 289 (1929–2026) TX 115 (1977–2026) IL 83 (1911–2026) FL 60 (1970–2026) DE 51 (1996–2026) NY 49 (1938–2026) WA 44 (1909–2025) OH 41 (1998–2026) PA 38 (1927–2026) MI 31 (2007–2025) CT 30 (1991–2026) AZ 28 (1969–2024) IA 28 (1976–2026) MO 27 (1986–2025) OR 26 (1909–2025) LA 26 (1982–2025) DC 22 (2001–2026) WI 22 (1997–2024) MD 22 (1986–2025) UT 18 (2002–2022) MA 17 (1927–2025) NC 16 (1896–2026) NJ 16 (1952–2025) VA 15 (1989–2025) GA 14 (1962–2026) MN 14 (1982–2025) MS 14 (1999–2024) CO 13 (1974–2026) AL 13 (1987–2023) NM 13 (1983–2023) SD 11 (1985–2024) IN 10 (1969–2025) AK 10 (1976–2025) ME 9 (1968–2022) MT 9 (1978–2016) ID 8 (1908–2025) WY 8 (2002–2025) ND 8 (1981–2014) KS 7 (2006–2026) HI 6 (1999–2024) SC 6 (2001–2025) KY 5 (2005–2024) NH 5 (1982–2025) TN 5 (1952–2020) NE 4 (1990–2024) OK 4 (2015–2022) WV 4 (2014–2024) NV 2 (2000–2025) RI 2 (2010–2010)

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.

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