Wyoming Statutes

Wyo. Stat. § 27-14-104 (2026)

Exclusive remedy as to employer; nonliability

✓ current as of May 2026

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of co-employees; no relief from liability; rights as to
delinquent or noncontributing employer.

     (a) The rights and remedies provided in this act for an
employee including any joint employee, and his dependents for
injuries incurred in extrahazardous employments are in lieu of
all other rights and remedies against any employer and any joint
employer making contributions required by this act, or their
employees acting within the scope of their employment unless the
employees intentionally act to cause physical harm or injury to
the injured employee, but do not supersede any rights and
remedies available to an employee and his dependents against any
other person.

     (b) No contract, rule, regulation or device shall operate
to relieve an employer from any liability created by this act
except as otherwise provided by this act.

     (c) This act does not limit or affect any right or action
by any employee and his dependents against an employer for
injuries received while employed by the employer when the
employer at the time of the injuries has not qualified under
this act for the coverage of his eligible employees, or having
qualified, has not paid the required premium on an injured
employee's earnings within thirty (30) days of the date due.
When an employee's employment starts within the same month as
the injury, the status of delinquency or not contributing shall
not apply until after the regular payroll reporting date.

Notes of Decisions

Cited in 55 cases (3 in the last 5 years), 1987–2026 · leading case: Mills v. Reynolds, 837 P.2d 48 (Wyo. 1992).

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Mills v. Reynolds, 837 P.2d 48 (Wyo. 1992). · cites it 121× “1977, as amended, Section 27-14-104, which grants immunity from suit to coemployees, violate Article 10, Section 4, of the Wyoming Constitution, which provides that "No law shall be enacted limiting the amount of damages to be recovered for causing the injury or death of any…”

Mills v. Reynolds, 807 P.2d 383 (Wyo. 1991). · cites it 86× “1977, as amended, Section 27-14-104, which grants immunity from suit to coemployees, violate Article 10, Section 4, of the Wyoming Constitution, which provides that `No law shall be enacted limiting the amount of damages to be recovered for causing the injury or death of any…”

Bertagnolli v. Louderback, 2003 WY 50 (Wyo. 2003). · cites it 15× “1 In Mills, we held § 27-14-104(3a) unconstitutional as it violated the equal protection clause of Article 3, Section 27 of the Wyoming Constitution by treating similarly situated people differently and violated Article 1, Section 8 of the Wyoming Constitution by denying aceess…”

Copp v. Redmond, 858 P.2d 1125 (Wyo. 1993). · cites it 14× “Effective February 18, 1993, this provision now reads: § 27-14-104. Exclusive remedy as to employer; nonliability of coemployees; no relief from liability; rights as to delinquent or noncontributing employer.”

Stuart v. Colorado Interstate Gas Co., 271 F.3d 1221 (10th Cir. 2001). · cites it 2× “See Wyo. Stat. Ann. § 27-14-104 (a) (Michie 2001).”

Loredo Ex Rel. Loredo v. Solvay Am., Inc., 2009 WY 93 (Wyo. 2009). · cites it 5× “Claims Against Co-employee Pacheco [¶16] Our usual standard of review for orders granting summary judgment applies here as well, and we will not repeat it in detail.”

Cardwell v. Am. Linen Supply, 843 P.2d 596 (Wyo. 1992). · cites it 8× “Cardwell states these issues: Is the termination of the Plaintiff after filing a Workers' Compensation Claim contrary to the public policy of the State of Wyoming as set forth in W.S. § 27-14-104? Was the termination of the Plaintiff contrary to the written policy of the…”

Formisano v. Gaston, 2011 WY 8 (Wyo. 2011). · cites it 11× “ISSUE [¶ 2] When viewed in the light most favorable to the appellant (Formisano), would the undisputed facts of this case allow a reasonable jury to find that the appellee (Gaston) intentionally acted to cause physical harm or injury to Formisano, as that concept is defined…”

Jose Ramirez v. Elvin Brown, Bill Wartenbee & Bryce Mitchell, 2020 WY 79 (Wyo. 2020). · cites it 8× “Ramirez sued his co-employee supervisors—Elvin Brown, Bill Wartenbee, and Bryce Mitchell—claiming they were liable for his injuries pursuant to Wyo. Stat. Ann. § 27-14-104 (a) of the Worker’s Compensation Act because they “intentionally act[ed] to cause physical harm or injury[.”

McDonald v. Mobil Coal Producing, Inc., 789 P.2d 866 (Wyo. 1990). · cites it 4× “See Wyo. Stat. § 27-14-104 (1977) (amended effective July 1, 1989).”

Griess v. Consol. Freightways Corp., 776 P.2d 752 (Wyo. 1989). · cites it 4× “Appellees argue that a tort remedy to vindicate this public policy is precluded by the portion of W.S. 27-14-104(a) which states that remedies under the act “are in lieu of all other rights and remedies * * The contention is that the employee has a single cause of action under…”

Baros v. Wells, 780 P.2d 341 (Wyo. 1989). · cites it 4× “[2] The current exclusive remedy provision of the Wyoming Worker's Compensation Act, Wyo. Stat. § 27-14-104 (1977), eliminates co-employee liability for culpable negligence.”

Show all 55 citing cases →

— Wyo. Stat. § 27-14-104(3a) — 1 case

Bertagnolli v. Louderback, 2003 WY 50 (Wyo. 2003). “1 In Mills, we held § 27-14-104(3a) unconstitutional as it violated the equal protection clause of Article 3, Section 27 of the Wyoming Constitution by treating similarly situated people differently and violated Article 1, Section 8 of the Wyoming Constitution by denying aceess…”

— Wyo. Stat. § 27-14-104(a) — 20 cases

Mills v. Reynolds, 837 P.2d 48 (Wyo. 1992). “1977, as amended, Section 27-14-104, which grants immunity from suit to coemployees, violate Article 10, Section 4, of the Wyoming Constitution, which provides that "No law shall be enacted limiting the amount of damages to be recovered for causing the injury or death of any…”

Mills v. Reynolds, 807 P.2d 383 (Wyo. 1991). “1977, as amended, Section 27-14-104, which grants immunity from suit to coemployees, violate Article 10, Section 4, of the Wyoming Constitution, which provides that `No law shall be enacted limiting the amount of damages to be recovered for causing the injury or death of any…”

Copp v. Redmond, 858 P.2d 1125 (Wyo. 1993). “Effective February 18, 1993, this provision now reads: § 27-14-104. Exclusive remedy as to employer; nonliability of coemployees; no relief from liability; rights as to delinquent or noncontributing employer.”

Loredo Ex Rel. Loredo v. Solvay Am., Inc., 2009 WY 93 (Wyo. 2009). “Claims Against Co-employee Pacheco [¶16] Our usual standard of review for orders granting summary judgment applies here as well, and we will not repeat it in detail.”

— Wyo. Stat. § 27-14-104(b) — 2 cases

Cardwell v. Am. Linen Supply, 843 P.2d 596 (Wyo. 1992). “Cardwell states these issues: Is the termination of the Plaintiff after filing a Workers' Compensation Claim contrary to the public policy of the State of Wyoming as set forth in W.S. § 27-14-104? Was the termination of the Plaintiff contrary to the written policy of the…”

Griess v. Consol. Freightways Corp., 776 P.2d 752 (Wyo. 1989). “Appellees argue that a tort remedy to vindicate this public policy is precluded by the portion of W.S. 27-14-104(a) which states that remedies under the act “are in lieu of all other rights and remedies * * The contention is that the employee has a single cause of action under…”

— Wyo. Stat. § 27-14-104(g) — 1 case

Circle C Resources, Inc. v. Kobielusz, 320 P.3d 213 (Wyo. 2014).

— Wyo. Stat. § 27-14-104(á) — 1 case

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