Wyoming Statutes

Wyo. Stat. § 16-4-404 (2026)

Types of meetings; notice; recess.

✓ current as of May 2026

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(a) In the absence of a statutory requirement, the
governing body of an agency shall provide by ordinance,
resolution, bylaws or rule for holding regular meetings unless
the agency's normal business does not require regular meetings
in which case the agency shall provide notice of its next
meeting to any person who requests notice. A request for notice
may be made for future meetings of an agency. The request shall
be in writing and renewed annually to the agency.

     (b) Special meetings may be called by the presiding
officer of a governing body by giving verbal, electronic or
written notice of the meeting to each member of the governing
body and to each newspaper of general circulation, radio or
television station requesting the notice. The notice shall
specify the time and place of the special meeting and the
business to be transacted and shall be issued at least eight (8)
hours prior to the commencement of the meeting. No other
business shall be considered at a special meeting. Proof of
delivery of verbal notice to the newspaper of general
circulation, radio or television station may be made by
affidavit of the clerk or other employee or officer of the
agency charged or responsible for distribution of the notice of
the meeting.

     (c) The governing body of an agency may recess any
regular, special, or recessed regular or special meeting to a
place and at a time specified in an order of recess. A copy of
the order of recess shall be conspicuously posted on or near the
door of the place where the meeting or recessed meeting was
held.

     (d) The governing body of an agency may hold an emergency
meeting on matters of serious immediate concern to take
temporary action without notice. Reasonable effort shall be made
to offer public notice. All action taken at an emergency meeting
is of a temporary nature and in order to become permanent shall
be reconsidered and acted upon at an open public meeting within
forty-eight (48) hours, excluding weekends and holidays, unless
the event constituting the emergency continues to exist after
forty-eight (48) hours. In such case the governing body may
reconsider and act upon the temporary action at the next
regularly scheduled meeting of the agency, but in no event later
than thirty (30) days from the date of the emergency action.

     (e) Day-to-day administrative activities of an agency, its
officers and its employees shall not be subject to the notice
requirements of this section.

Notes of Decisions

Cited in 7 cases, 1990–2016 · leading case: Cheyenne Newspapers, Inc., d/b/a the Wyoming Tribune-Eagle, a Wyoming Corp. v. City of Cheyenne, Wyoming, 2016 WY 125 (Wyo. 2016).

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Cheyenne Newspapers, Inc., d/b/a the Wyoming Tribune-Eagle, a Wyoming Corp. v. City of Cheyenne, Wyoming, 2016 WY 125 (Wyo. 2016). · cites it 2× “Wyo. Stat. Ann. § 16-4-404 (e). Because it would be cumbersome to impose open meeting requirements on every administrative activity, the legislature limited the Act to “meetings of the governing body of an agency.”

Fontaine v. Bd. of Cnty. Com'rs of Park Cnty., 4 P.3d 890 (Wyo. 2000). · cites it 2× “In her appellate brief, Fontaine boldly asserts: When the Court examines the supporting exhibits, it is apparent that the discussions at staff meetings and work sessions go well beyond "discussing the day to day administrative activities of the agency" as mentioned in W.S. §…”

Worker's Comp. Claim of Decker v. State Ex Rel. Wyoming Med. Comm'n, 2008 WY 100 (Wyo. 2008). · cites it 2× “§ 16-4-404. Types of meetings; notice; recess.”

Palmer v. Crook Cnty. Sch. Dist. 1, 785 P.2d 1160 (Wyo. 1990). · cites it 2× “The District counters Palmer’s claim with evidence of compliance with W.S. 16-4-404(b) (Oct. 1982 Repl.). 3 The District argues that express notice of “hiring professional staff,” in conjunction with Palmer’s constructive notice of the purpose of the meeting and community…”

Ward v. Bd. of Trs. of Goshen Cnty. Sch. Dist. No. 1, 865 P.2d 618 (Wyo. 1993). “] It is undisputed that the April 2 and 6 meetings do not satisfy the notice requirements of W.S. 16-4-404 (1990). Thus we are confronted with the question: What action, if any, taken at those meetings is void as provided in W.”

Kanahele v. Maui Cnty. Council., 307 P.3d 1174 (Haw. 2013). “§ 703 (West, Westlaw through 2004 Act 88) (for a recessed or reconvened meeting, notice must be posted "prominently at the principal office of the agency holding the meeting or at the public building in which the meeting is to be held”); Wyo.”

Deering v. Bd. Dirs. Fremont Cty. Lib., 954 P.2d 1359 (Wyo. 1998). · cites it 2× “The term “emergency meeting” also appears in the Act, Wyo. Stat. § 16-4-404(d) (1997), but without express definition.”

— Wyo. Stat. § 16-4-404(b) — 1 case

Palmer v. Crook Cnty. Sch. Dist. 1, 785 P.2d 1160 (Wyo. 1990). “The District counters Palmer’s claim with evidence of compliance with W.S. 16-4-404(b) (Oct. 1982 Repl.). 3 The District argues that express notice of “hiring professional staff,” in conjunction with Palmer’s constructive notice of the purpose of the meeting and community…”

— Wyo. Stat. § 16-4-404(d) — 1 case

Deering v. Bd. Dirs. Fremont Cty. Lib., 954 P.2d 1359 (Wyo. 1998). “The term “emergency meeting” also appears in the Act, Wyo. Stat. § 16-4-404(d) (1997), but without express definition.”

— Wyo. Stat. § 16-4-404(e) — 1 case

Fontaine v. Bd. of Cnty. Com'rs of Park Cnty., 4 P.3d 890 (Wyo. 2000). “In her appellate brief, Fontaine boldly asserts: When the Court examines the supporting exhibits, it is apparent that the discussions at staff meetings and work sessions go well beyond "discussing the day to day administrative activities of the agency" as mentioned in W.S. §…”

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