Wyoming Statutes

Wyo. Stat. § 1-3-107 (2026)

Act, error or omission in rendering professional

✓ current as of May 2026

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or health care services.

     (a) A cause of action arising from an act, error or
omission in the rendering of licensed or certified professional
or health care services shall be brought within the greater of
the following times:

          (i) Within two (2) years of the date of the alleged
act, error or omission, except that a cause of action may be
instituted not more than two (2) years after discovery of the
alleged act, error or omission, if the claimant can establish
that the alleged act, error or omission was:
                  (A)   Not reasonably discoverable within a two (2)
year period; or

               (B) The claimant failed to discover the alleged
act, error or omission within the two (2) year period despite
the exercise of due diligence.

          (ii) For injury to the rights of a minor, by his
eighth birthday or within two (2) years of the date of the
alleged act, error or omission, whichever period is greater,
except that a cause of action may be instituted not more than
two (2) years after discovery of the alleged act, error or
omission, if the claimant can establish that the alleged act,
error or omission was:

               (A) Not reasonably discoverable within the two
(2) year period; or

               (B) That the claimant failed to discover the
alleged act, error or omission within the two (2) year period
despite the exercise of due diligence.

          (iii) For injury to the rights of a plaintiff
suffering from a legal disability other than minority, within
one (1) year of the removal of the disability;

          (iv) If under paragraph (i) or (ii) of this
subsection, the alleged act, error or omission is discovered
during the second year of the two (2) year period from the date
of the act, error or omission, the period for commencing a
lawsuit shall be extended by six (6) months.

     (b) This section applies to all persons regardless of
minority or other legal disability.

Notes of Decisions

Cited in 62 cases (8 in the last 5 years), 1982–2026 · leading case: Metzger v. Kalke, 709 P.2d 414 (Wyo. 1985).

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Metzger v. Kalke, 709 P.2d 414 (Wyo. 1985). · cites it 36× “The district court dismissed appellants' claims against Hussain as barred by the statute of limitations applicable to medical tort actions, § 1-3-107, W.S. 1977. The court granted Kalke's motion for summary judgment on the dual grounds that no dispute of material fact existed as…”

Wyo. Guardianship Corp. v. Wyo. State Hosp., 428 P.3d 424 (Wyo. 2018). · cites it 22× “Do the notice and filing requirements of the Wyoming Governmental Claims Act extend the medical malpractice statute of limitations in Wyo. Stat. Ann. § 1-3-107 ? 2 Did Ms. Gelok's Complaint allege sufficient facts to state a claim for relief under 42 U.”

Merry Candelaria v. Mahesh Karandikar, M.D., 2020 WY 140 (Wyo. 2020). · cites it 23× “Karandikar was barred by the statute of limitations under Wyo. Stat. Ann. § 1-3-107 ? FACTS [¶3] Merry Candelaria began seeing Dr.”

Bredthauer v. TSP, 864 P.2d 442 (Wyo. 1993). · cites it 22× “That order stated, in part: The parties agree that the provisions of W.S. § 1-3-107 state the applicable period of limitations with respect to all claims against the Defendants CSSA and TSP.”

Garret & Shelly Falkenburg v. Laramie Inv. Co., Inc. & Brad M. Jackson, 2023 WY 78 (Wyo. 2023). · cites it 27× “§ 1-3-107? II. When did the statute of limitations begin to run? III.”

Bankers Stand. Ins. Co., a Pennsylvania Co. v. Jtec, Inc., a Wyoming Corp., 2025 WY 51 (Wyo. 2025). · cites it 55× “The question asks when a professional’s act, error, or omission occurred under Wyo. Stat. Ann. § 1-3-107 (2023) where a professional engineer allegedly designed a defective component in a water system and documented the alleged defect in multiple sets of plans.”

Seneca Ins. Co., Inc., a foreign Corp., 2014 WY 145 (Wyo. 2014). · cites it 21× “They also moved to dismiss the complaint under Rule 12(b)(6), asserting that the complaint was not filed within the two-year statute of limitations for "professional malpractice" under Wyo. Stat. Ann. § 1-3-107 2 The motions were heard at a final pretrial conference held on…”

Bylin v. Billings, 568 F.3d 1224 (10th Cir. 2009). · cites it 5× “The district court concluded their claims were time-barred under the two-year statute of limitations set forth in Wyo. Stat. Ann. § 1-3-107 (a). We have jurisdiction under 28 U.”

Prokop v. Hockhalter, 2006 WY 75 (Wyo. 2006). · cites it 17× “Wyo. Stat. Ann. § 1-3-107 (a) requires that actions "arising from an act, error or omission in the rendering of licensed or certified professional or health care services be brought within .”

Adelizzi v. Stratton, 2010 WY 148 (Wyo. 2010). · cites it 13× “When did the limitation period for professional negligence begin to run under Wyo. Stat. Ann. § 1-3-107 (LexisNexis 2009)? 2.”

Pioneer Homestead Apts. III v. Sargent Eng'rs, Inc., 421 P.3d 1074 (Wyo. 2018). · cites it 12× “The court did not specifically discuss Pioneer's supporting affidavits, but concluded: For an extension of the two-year limitation to apply under Wyo. Stat. Ann. § 1-3-107 (a)(i), the Plaintiffs have the burden of establishing either that the alleged act, error or omission was…”

Lucky Gate Ranch, L.L.C. v. Baker & Assocs., Inc., 2009 WY 69 (Wyo. 2009). · cites it 16× “§ 1-8-107 is the relevant statute of limitations but contends that its cause of action accrued on or after May 11, 2005 and that its complaint was timely filed within the two-year limitation period provided by Wyo. Stat. Ann. § 1-3-107 . 1 [T¢11] The district court, reviewing…”

Show all 62 citing cases →

— Wyo. Stat. § 1-3-107(1997) — 1 case

Edwards v. Fogarty, 962 P.2d 879 (Wyo. 1998).

— Wyo. Stat. § 1-3-107(a) — 13 cases

Metzger v. Kalke, 709 P.2d 414 (Wyo. 1985). “The district court dismissed appellants' claims against Hussain as barred by the statute of limitations applicable to medical tort actions, § 1-3-107, W.S. 1977. The court granted Kalke's motion for summary judgment on the dual grounds that no dispute of material fact existed as…”

Prokop v. Hockhalter, 2006 WY 75 (Wyo. 2006). “Wyo. Stat. Ann. § 1-3-107 (a) requires that actions "arising from an act, error or omission in the rendering of licensed or certified professional or health care services be brought within .”

Rawlinson v. Greer, 2003 WY 28 (Wyo. 2003).

Rawlinson v. Cheyenne Bd. of Pub. Utils., 2001 WY 6 (Wyo. 2001).

Merry Candelaria v. Mahesh Karandikar, M.D., 2020 WY 140 (Wyo. 2020). “Karandikar was barred by the statute of limitations under Wyo. Stat. Ann. § 1-3-107 ? FACTS [¶3] Merry Candelaria began seeing Dr.”

— Wyo. Stat. § 1-3-107(a)(i) — 11 cases

Bredthauer v. TSP, 864 P.2d 442 (Wyo. 1993). “That order stated, in part: The parties agree that the provisions of W.S. § 1-3-107 state the applicable period of limitations with respect to all claims against the Defendants CSSA and TSP.”

Adelizzi v. Stratton, 2010 WY 148 (Wyo. 2010). “When did the limitation period for professional negligence begin to run under Wyo. Stat. Ann. § 1-3-107 (LexisNexis 2009)? 2.”

Sharsmith v. Hill, 764 P.2d 667 (Wyo. 1988).

Edwards v. Fogarty, 962 P.2d 879 (Wyo. 1998).

— Wyo. Stat. § 1-3-107(a)(i)(B) — 1 case

Alan G. Moats & Chleo I. Moats v. Prof'l Assistance, LLC, d/b/a Summit Title Servs., Kuzma Success Realty, & P. Olen Snider, Jr., 2014 WY 6 (Wyo. 2014).

— Wyo. Stat. § 1-3-107(a)(iii) — 1 case

Dana v. Anderson, 163 F. Supp. 3d 1143 (D. Wyo. 2016).

— Wyo. Stat. § 1-3-107(a)(iv) — 4 cases

Bankers Stand. Ins. Co., a Pennsylvania Co. v. Jtec, Inc., a Wyoming Corp., 2025 WY 51 (Wyo. 2025). “The question asks when a professional’s act, error, or omission occurred under Wyo. Stat. Ann. § 1-3-107 (2023) where a professional engineer allegedly designed a defective component in a water system and documented the alleged defect in multiple sets of plans.”

Nobles v. Mem'l Hosp. of Laramie Cnty., 301 P.3d 517 (Wyo. 2013).

Ted Nobles v. Mem'l Hosp. of Laramie Cnty., d/b/a United Med. Ctr. & d/b/a Cheyenne Reg'l Med. Ctr. & the Bd. of Trs. of Mem'l Hosp. of Laramie Cnty., d/b/a United Med. Ctr. & d/b/a Cheyenne Reg'l Med. Ctr., 2013 WY 66 (Wyo. 2013).

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