WYOMING AUTHORITY LIBRARY

Wyoming Case Authority Library

A research index of Wyoming statutes and judicial decisions governing automobile insurance, crash liability, UM/UIM coverage, claims handling, policy interpretation, insured status, settlement, damages and related recovery issues.

How This Library Classifies Authority

Principal Wyoming Doctrinal Chains

Coverage Disclosure

First-Party Bad Faith

UM/UIM & Stacking

Mandatory Coverage / Exclusions

Agent / Procurement Duties

Third-Party Failure to Settle

Crash Liability

Duty to Defend

Current Statutory Framework

Search the Case Authority Index

51 authorities shown

McCullough v. Golden Rule Insurance Co.

Foundational Wyoming first-party bad-faith case. Establishes the absence-of-reasonable-basis plus knowledge/reckless-disregard framework and the objective fairly-debatable standard.

Darlow v. Farmers Insurance Exchange

Auto/MedPay authority applying first-party bad-faith principles and recognizing circumstances in which an insurer must inform its insured about available policy coverage.

State Farm v. Shrader

Major UM authority permitting direct action against the UM carrier and forming part of Wyoming’s coverage-disclosure and first-party good-faith line.

Cathcart v. State Farm

Principal first-party UM coverage-disclosure case. Emphasizes the insurer’s duty to inform its insured of the extent of available coverage before settlement, particularly when the insured lacks that knowledge.

Bergantino v. State Farm

Modern UIM authority enforcing the policy’s definition of underinsured vehicle while reaffirming Wyoming’s insurance-contract and coverage-information principles.

Broderick v. Dairyland Insurance Co.

Confirms Wyoming does not statutorily mandate UIM and warns that requesting “full coverage” does not create insurance absent from the written policy.

Aaron v. State Farm

Principal Wyoming multiple-policy UIM stacking case. Requires clear limitations on aggregation and rejects repeated credit for a single tortfeasor payment.

Ramsour v. Grange Insurance Association

Foundational inter-policy UM stacking authority. Separate coverage may contribute toward actual uncompensated damages but cannot produce recovery above the actual loss.

Commercial Union Insurance Co. v. Stamper

Principal intra-policy stacking case. Enforces clear language limiting recovery despite several covered vehicles under one policy.

State ex rel. Farmers v. District Court

UIM authority involving policy treatment where tortfeasor liability limits and UIM limits were equal.

Eklund v. Farmers Insurance Exchange

UIM carrier that preserved its rights and did not participate in the tort settlement was not automatically bound by stipulated damages.

Ulrich v. USAA

Addresses the causal nexus required for UM coverage arising out of ownership, maintenance, or use of a vehicle.

Hatch v. State Farm

Investigation matters to the fairly-debatable inquiry. An insurer cannot avoid scrutiny by failing to develop or recklessly ignoring facts necessary to evaluate the claim.

Farmers Insurance Exchange v. Shirley

MedPay and delay authority addressing bad-faith damages, emotional injury, and the higher showing required for punitive damages.

Matlack v. Mountain West Farm Bureau

Important bad-faith and duty-to-defend authority addressing potentially covered allegations and Wyoming’s insurance standards.

Doctors’ Co. v. Insurance Corp. of America

Foundational Wyoming policy-interpretation authority: plain meaning, policy as a whole, ambiguity against the insurer, but no manufactured ambiguity.

Allstate Insurance Co. v. Wyoming Insurance Department

Compulsory-insurance authority preventing household exclusions from eliminating Wyoming’s statutory minimum liability protection.

Martin v. Farmers Insurance Exchange

Enforces clear household exclusion above Wyoming’s statutory minimum while preserving the compulsory-insurance floor.

Pribble v. State Farm

Reaffirms enforceability of clear household exclusions above the mandatory minimum and limits reasonable-expectations arguments where policy language is unambiguous.

Century Surety Co. v. Jim Hipner, LLC

Adopts Wyoming’s notice-prejudice rule and demonstrates that public policy can override clear policy language purporting to eliminate coverage solely for late notice.

Hursh Agency, Inc. v. Wigwam Homes, Inc.

Foundational failure-to-procure authority requiring reasonable skill, care, and diligence when an agent undertakes to obtain specified insurance.

Gordon v. Spectrum, Inc.

Ordinary insurance agents have no universal continuing duty to discover every coverage gap; a special relationship may alter the analysis.

Feather v. State Farm

Automobile authority applying the duty to read insurance documents and addressing newly acquired vehicle coverage.

Mendenhall v. Mountain West

Certificate of title is important but not necessarily conclusive proof of actual vehicle ownership for coverage analysis.

Phoenix Assurance Co. v. Latta

Implied permission may arise from course of conduct and surrounding circumstances.

Wyoming Farm Bureau v. May

Express restrictions on permission can prevent a first permittee from extending insured use to a second driver.

Jack v. Enterprise Rent-A-Car

Rejects automatic rental-owner liability while recognizing that independent negligent-entrustment theories require their own proof.

Shafer v. TNT Well Service, Inc.

Treats negligent entrustment as an independent theory rather than merely another label for respondeat superior.

Oberson v. Shreeve

Comparative-fault authority demonstrating that a traffic violation does not eliminate comparative analysis of the conduct of all drivers.

Roberts v. Estate of Randall

Treats sudden emergency as a circumstance within ordinary reasonable-care analysis; the driver cannot negligently create the emergency relied upon.

Cardenas v. Fossen

Collision or loss of control does not itself compel a negligence finding when the circumstances permit more than one reasonable inference.

Bunning v. Romero

Current motor-vehicle comparative-fault authority. A preferred driver with the right of way still owes reasonable care, and speeding or unsafe driving can support fault allocation.

Banks v. Crowner

Supports recovery of the reasonable value of necessary medical services even where the services were furnished gratuitously.

Rudy v. Bossard

Future medical damages may be submitted when the substance of the evidence establishes that future care is more likely than not.

Union Pacific Railroad v. Richards

Distinguishes impairment of future earning capacity from actual wages already lost.

Weaver v. Mitchell

Recognizes spousal loss of consortium and its derivative relationship to the injured spouse’s comparative fault.

Kendrick v. Barker

Principal settlement-finality warning. A negotiated personal-injury settlement may remain enforceable despite later discovery of a more serious injury.

Haderlie v. Sondgeroth

Modern post-joint-liability settlement authority rejecting an automatic dollar-for-dollar credit where settled actors were assigned no fault.

Stilson v. Hodges

Automobile subrogation and assignment authority involving medical payments and an insurer’s asserted interest in tort recovery.

Knowles v. Corkill

Principal wrongful-death damages authority distinguishing loss of probable future companionship, society and comfort from nonrecoverable grief or mental anguish as separate damage categories.

Farmers Insurance Exchange v. Dahlheimer

Multiple wrongful-death beneficiaries did not multiply the UM per-person limit where only the decedent sustained bodily injury.

Hamlin v. Transcon Lines

Foundational governmental motor-vehicle waiver authority under the Wyoming Governmental Claims Act.

DeWald v. State

Police-pursuit authority demonstrating that waiver of immunity does not eliminate the need to prove negligence and proximate causation.

Bain v. City of Cheyenne

Modern authority upholding the Governmental Claims Act’s individual liability limitation as a boundary on Wyoming’s waiver of sovereign immunity.

Aetna Insurance Co. v. Lythgoe

Foundational Wyoming rule that the duty to defend is broader than the ultimate duty to indemnify.

First Wyoming Bank v. Continental Insurance Co.

Final rehearing opinion. Compares underlying allegations to policy coverage and confirms that pleading labels do not manufacture a covered occurrence.

Shoshone First Bank v. Pacific Employers

One potentially covered claim can require defense of the entire action; a reservation letter cannot unilaterally create a defense-cost reimbursement right absent policy support.

Western Casualty & Surety Co. v. Fowler

Foundational third-party failure-to-settle authority requiring intelligent, honest judgment and appropriate consideration of the insured’s personal exposure.

Herrig v. Herrig

Insurer’s good-faith duty runs to its insured, not the adverse claimant; Wyoming’s unfair-claims statute does not create an implied private third-party action.

Jarvis v. Farmers Insurance Exchange

Declines to extend Wyoming’s traditional failure-to-settle tort where the insured never became subject to a qualifying excess judgment.

GAINSCO Insurance Co. v. Amoco Production Co.

Major failure-to-settle authority addressing objective settlement evaluation, assignment of insured rights, excess judgments and covenants not to execute.

Federal Cases Applying Wyoming Law

Curtis v. State Farm

Federal authority applying Wyoming permission principles in a second-permittee automobile coverage dispute.

State Farm v. Dyer

Federal decision applying Wyoming law to permissive-user and employee/fellow-employee exclusion issues.

Liberty Mutual v. Cincinnati Insurance Co.

Current federal application of Wyoming’s potential-coverage duty-to-defend framework.

Historical & QC Cautions

Use Haderlie rather than pre-1986 contribution cases for the modern settlement-credit structure.
Use the final rehearing opinion in First Wyoming Bank, 1993 WY 126, rather than the superseded earlier opinion.
Ragsdale v. Hartford is procedural: the appeal was dismissed as untimely and is not a merits holding on the disputed subrogation issue.
Federal cases such as Dyer and Curtis must be labeled federal authority applying Wyoming law.
Do not treat absence of a case in this library as proof that no Wyoming authority exists.