Wyoming Statutes

Wyo. Stat. § 2-6-112 (2026)

Will to be in writing; number and competency of

✓ current as of May 2026
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witnesses; signature of testator; subscribing witness not to
benefit; exception.

     (a) Except as provided in W.S. 2-6-113, all wills to be
valid shall be in writing, or typewritten, witnessed by two (2)
competent witnesses and signed by the testator or by some person
in his presence and by his express direction. If the witnesses
are competent at the time of attesting the execution of the
will, their subsequent incompetency shall not prevent the
probate and allowance of the will. No subscribing witness to any
will can derive any benefit therefrom unless there are two (2)
disinterested and competent witnesses to the same, but if
without a will the witness would be entitled to any portion of
the testator's estate, the witness may still receive the portion
to the extent and value of the amount devised.

     (b) Witnesses to a will may appear in person or by the use
of audio-video communication technology, provided that the
witnesses can see and hear the testator in real time, have the
opportunity to judge the competency of the testator, have the
ability to securely sign the will electronically and can
determine that the testator is freely and voluntarily signing
and executing the will.
Notes of Decisions
Meyer v. Fanning, 367 P.3d 629 (Wyo. 2016). · cites it 18× “The court rejected this argument, holding that "Compliance with the minimum requirements of Wyo. Stat. § 2-6-112 for a will does not prove a will.”
Matter of Est. of Zelikovitz, 923 P.2d 740 (Wyo. 1996). · cites it 13× “) The statute refers to Wyo. Stat. § 2-6-112 (1980), which provides, in pertinent part: Except as provided in the next section [§ 2-6-113], all wills to be valid shall be in writing, or typewritten, witnessed by two (2) competent witnesses and signed by the testator or by some…”
In Re Est. of Seader, 2003 WY 119 (Wyo. 2003). · cites it 4× “Wyo. Stat. Ann. § 2-6-112 (LexisNexis 2003), which requires wills to be in writing, precludes ascribing to a testator any intention not expressed in the instrument itself.”
Russell v. Sullivan, 270 P.3d 677 (Wyo. 2012). · cites it 5× “He adopted and incorporated by reference the claims and allegations in the neighbors' petition, including the assertion that the will was invalid under Wyo. Stat. Ann. § 2-6-112 (LexisNexis 2011) and should not have been admitted to probate because it had not been witnessed by…”
Matter of Est. of Campbell, 673 P.2d 645 (Wyo. 1983). · cites it 5× “The question argued by the parties in their briefs is whether the district court properly applied the provisions of § 2-6-112, W.S. 1977, [1] in holding that the bequests made to the appellants-Dibbles in the codicil to the will of the decedent which was executed on August 5,…”
Seeley v. in Re the Est. of Seeley, 627 P.2d 1357 (Wyo. 1981). · cites it 10× “Section 2-6-116 of the Wyoming Probate Code adopted in 1980 would seem to settle such matters, if a conflict should exist: "A written will is valid if executed in compliance with W.S. 2-6-112 or 2-6-113 or if its execution complies with the law at the time of execution of the…”
Matter of Est. of Croft, 713 P.2d 782 (Wyo. 1986). · cites it 2× “* * * ” Section 2-6-112, W.S.1977 (July 1980 Replacement), provides in part that “all wills to be valid shall be in writing.”
Matter of Est. of Reed, 672 P.2d 829 (Wyo. 1983). · cites it 2× “Section 2-6-112, W.S. 1977, provides in part: "Except as provided in the next section [§ 2-6-113], all wills to be valid shall be in writing, or typewritten, witnessed by two (2) competent witnesses and signed by the testator or by some person in his presence and by his express…”
Baker v. Enis, 114 P.3d 1246 (Wyo. 2005). · cites it 2× “Wyo. Stat. Ann. § 2-6-112 (LexisNexis 2003), which requires wills to be in writing, precludes ascribing to a testator any intention not expressed in the instrument itself.”
Matter of Est. of Altman, 650 P.2d 277 (Wyo. 1982). “The pertinent issue is whether or not the subscribing witnesses to the will, Marty Fernau and Gemila Stetson, each signed the will under the conditions prescribed by § 2-6-112, W.S. 1977. Such section provides in pertinent part: "* * * [A]ll wills to be valid shall be in…”
Watson v. Dailey, 673 P.2d 645 (Wyo. 1983). · cites it 5× “The question argued by the parties in their briefs is whether the district court properly applied the provisions of § 2-6-112, W.S.1977, 1 in holding that the bequests made to the appellants-Dibbles in the codicil to the will of the decedent which was executed on August 5, 1980,…”
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