Wyo. Stat. » Wyo. Stat. / Title 01 - Civil Procedure / Chapter 39 - GOVERNMENTAL CLAIMS / Article 4 - SPECIFIC PERFORMANCE; ACTIONS FOR
Wyoming Statutes

Wyo. Stat. § 1-39-112 (2026)

Liability; peace officers.

✓ current as of May 2026
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A governmental entity is liable for damages resulting from
tortious conduct of peace officers while acting within the scope
of their duties.
Notes of Decisions
Cited in 34 cases (5 in the last 5 years), 1983–2025 · leading case: Natrona Cnty. v. Blake, 2003 WY 170 (Wyo. 2003).
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Natrona Cnty. v. Blake, 2003 WY 170 (Wyo. 2003). · cites it 19× “DISCUSSION [¶ 10] Pertinent to this appeal, Blake's wrongful death claim was brought under the Wyoming Governmental Claims Act (WGCA), Wyo. Stat. Ann. § 1-39-112 ("... tortious conduct of peace officers acting within the scope of their duties.”
Cooney v. Park Cnty., 792 P.2d 1287 (Wyo. 1990). · cites it 22× “They argued that the only applicable exception the Cooneys could assert would be the one set out in W.S. 1-39-112 (Cum.Supp. 1985), which provided: "A governmental entity is liable for damages resulting from tortious conduct of law enforcement officers while acting within the…”
DeWald v. State, 719 P.2d 643 (Wyo. 1986). · cites it 14× “" Section 1-39-112, W.S. 1977, Cum.Supp. 1985.”
Calli Cornella, Phillip Cornella, & Calli & Phillip Cornella as Next Friends of Jpc, Bnc & Spc v. City of Lander, Wyoming, 2022 WY 9 (Wyo. 2022). · cites it 14× “§ 15-1-103 (a)(l) (LexisNexis 2021) authorizes “[t]he governing bodies of all cities and towns” to “[a]ppoint special municipal officers” such as animal control officers, “who are not certified as 3 [summary judgment] issue from the existence of a duty to the focus of whether…”
Matthews v. Wyoming Dep't of Agric., 719 P.2d 216 (Wyo. 1986). · cites it 16× “" Appellees also discussed § 1-39-112, the law enforcement exception, which states: "A governmental entity is liable for damages resulting from tortious conduct of law enforcement officers while acting within the scope of their duties.”
Carabajal v. City of Cheyenne, WY, 847 F.3d 1203 (10th Cir. 2017). · cites it 2× “Wyo. Stat. Ann. § 1-39-112 . Wyoming law further recognizes the tort of negligent hiring, in which an entity may be liable for the conduct of its agents if the entity is negligent or reckless in the employment of improper persons in work that poses a risk of harm to others.”
Rice v. Collins Commc'n, Inc., 2010 WY 109 (Wyo. 2010). · cites it 8× “§ 1-39-106; or for peace officers in Wyo. Stat. § 1-39-112 (1988). Huitt , 844 P.”
State v. Dieringer, 708 P.2d 1 (Wyo. 1985). · cites it 6× “* *" Kinniburgh concedes that § 1-39-112, W.S. 1977 (1985 Cum.Supp.), provides: "A governmental entity is liable for damages resulting from tortious conduct of law enforcement officers while acting within the scope of their duties.”
Hurst v. State, 698 P.2d 1130 (Wyo. 1985). · cites it 4× “That statute, § 1-39-112, W.S.1977, Cum.Supp.1984, provides: “A governmental entity is liable for damages resulting from tortious conduct of law enforcement officers while acting within the scope of their duties.”
Keehn v. Town of Torrington, 834 P.2d 112 (Wyo. 1992). · cites it 4× “Section 1-39-112 provides that “[a] governmental entity is liable for damages resulting from tortious conduct of peace officers while acting within the scope of their duties.” The litigants do not dispute that Officer Schuppan was a peace officer acting within the scope of his…”
Charles Leonhardt v. Big Horn Cnty. Sheriff's Off.; Big Horn Cnty. Jail; Sheriff Ken Blackburn; & Captain Debbie Cook, 2024 WY 128 (Wyo. 2024). · cites it 5× “” Wyo. Stat. Ann. § 1-39-112 . “Peace officer” includes sheriffs and detention officers, Wyo.”
Becker v. Mason, 2006 WY 143 (Wyo. 2006). · cites it 6× “" Second, the district court noted that the evaluation of a peace officer's conduct under Wyo. Stat. Ann. § 1-39-112 requires application of general tort law principles.”
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