[// GUIDANCE: Replace every bracketed ALL-CAPS placeholder with precise, fact-specific information.
Delete any bracketed “OPTIONAL” sections that do not apply.
Ensure all allegations satisfy Rule 11, investigative, and evidentiary duties. ]

=====================================================================
IN THE DISTRICT COURT OF
[_] COUNTY, STATE OF WYOMING
=====================================================================
[PLAINTIFF FULL LEGAL NAME], )
) Civil Action No. _____
Plaintiff, )
)
v. ) COMPLAINT FOR DAMAGES
) (Personal Injury – Motor Vehicle Collision)
[DEFENDANT FULL LEGAL NAME], )
[ADDITIONAL DEFENDANTS], ) JURY TRIAL DEMANDED
)
Defendants. )
)

COMPLAINT

Plaintiff [PLAINTIFF] (“Plaintiff”), by and through undersigned counsel, alleges for his/her Complaint against Defendant(s) as follows:

TABLE OF CONTENTS

1. Parties .............................................................................. ¶¶ 1–4
2. Jurisdiction & Venue .................................................... ¶¶ 5–7
3. Definitions .................................................................... ¶¶ 8–11
4. Factual Allegations ................................................... ¶¶ 12–27
5. Causes of Action
   • Count I – Negligence ............................................ ¶¶ 28–38
   • Count II – Negligence Per Se (OPTIONAL) ............. ¶¶ 39–45
   • Count III – Vicarious Liability (OPTIONAL) ........... ¶¶ 46–52
6. Damages ......................................................................... ¶¶ 53–57
7. Prayer for Relief ........................................................... ¶ 58
8. Jury Demand ................................................................. ¶ 59
9. Verification & Rule 11 Certification (OPTIONAL) ..... ¶ 60
10. Certificate of Service ................................................ ¶ 61

1. PARTIES

1. Plaintiff [PLAINTIFF], an adult individual, is and at all relevant times was a resident of [COUNTY], State of Wyoming.
2. Defendant [DEFENDANT DRIVER] (“Driver”) is an adult individual residing at [ADDRESS] and may be served at [SERVICE ADDRESS].
3. Defendant [DEFENDANT OWNER] (“Owner”) is a [corporation/LLC/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS].
4. [ADDITIONAL PARTY ALLEGATIONS, e.g., employer, governmental entity, uninsured/under-insured motorist carrier.]

2. JURISDICTION & VENUE

5. This Court has subject-matter jurisdiction under Wyo. Const. art. 5, § 10 and WYO. STAT. ANN. § 5-3-101 because the amount in controversy exceeds the jurisdictional minimum and the cause of action arises within this County.
6. Venue is proper in this Court pursuant to WYO. STAT. ANN. § 1-5-101 because Defendant resides in, and the collision giving rise to these claims occurred in, [_] County.
7. Personal jurisdiction over each Defendant exists because each Defendant is domiciled in, conducts substantial business within, or committed tortious acts within the State of Wyoming.

3. DEFINITIONS [// GUIDANCE: Use only those that assist clarity.]

8. “Accident” means the motor-vehicle collision that occurred on [DATE] at or near [LOCATION].
9. “Subject Vehicle(s)” means the motor vehicle(s) operated by the parties in the Accident.
10. “Injury” means the bodily injury and resulting impairments sustained by Plaintiff as described herein.
11. “Comparative Fault” refers to the apportionment of negligence required under WYO. STAT. ANN. § 1-1-109.

4. FACTUAL ALLEGATIONS

12. On [DATE] at approximately [TIME], Plaintiff lawfully operated the Subject Vehicle eastbound on [ROADWAY] approaching the intersection with [CROSS-STREET] in [CITY], Wyoming.
13. Defendant Driver, operating a [MAKE/MODEL/YEAR], negligently [describe conduct: e.g., “failed to stop at a red light” / “drove left of center”].
14. Defendant’s negligent act(s) caused a violent impact with Plaintiff’s vehicle.
15. At the time of the Accident, weather, traffic, and roadway conditions were [describe].
16. Defendant Driver was acting within the course and scope of employment with Defendant Owner, and/or Defendant Owner negligently entrusted the Subject Vehicle to Driver.
17. Plaintiff was wearing an appropriate seatbelt and otherwise exercising reasonable care for his/her own safety.
18. As a direct and proximate result of Defendants’ negligence, Plaintiff sustained severe and permanent injuries including but not limited to [list specific injuries].
19. Plaintiff has incurred medical expenses in excess of $[AMOUNT] to date and anticipates future medical costs.
20. Plaintiff has suffered lost wages and loss of future earning capacity estimated at $[AMOUNT].
21. Plaintiff has suffered and will continue to suffer physical pain, mental anguish, loss of enjoyment of life, and other non-economic damages.
22. Wyoming follows a fault-based tort system for auto collisions; no statutory no-fault limitations apply.
23. Under Wyoming’s modified comparative negligence statute, WYO. STAT. ANN. § 1-1-109, Plaintiff’s recovery is barred only if Plaintiff’s proportion of fault equals or exceeds that of Defendants.
24. Plaintiff’s fault, if any, was less than 50 percent of the total fault.
25. No statutory cap applies to economic or noneconomic damages for automobile-related personal injuries in Wyoming.
26. All conditions precedent to the filing of this action have been satisfied, waived, or otherwise discharged.
27. Plaintiff reserves the right to amend pleadings upon discovery of additional facts.

5. CAUSES OF ACTION

COUNT I – NEGLIGENCE (Against All Defendants)

28. Plaintiff realleges ¶¶ 1–27.
29. Defendants owed Plaintiff a duty of reasonable care in operating, maintaining, and entrusting the Subject Vehicle.
30. Defendants breached said duty by, inter alia, [list specific statutory/regulatory violations or acts/omissions].
31. The breach was the direct and proximate cause of the Accident and Plaintiff’s injuries.
32. Plaintiff suffered the damages described herein as a foreseeable result of Defendants’ negligence.
33. Pursuant to WYO. STAT. ANN. § 1-1-109, Plaintiff’s comparative fault, if any, does not bar recovery.
34. Therefore, Plaintiff demands judgment against Defendants, joint and several, for all damages as allowed by law.
    35.–38. [// GUIDANCE: Insert additional breach particulars, e.g., speeding (WYO. STAT. ANN. § 31-5-301), failure to yield (§ 31-5-222), etc., if pleading negligence per se separately omit here.]

COUNT II – NEGLIGENCE PER SE (Traffic-Statute Violation) (OPTIONAL)

39. Plaintiff realleges ¶¶ 1–38.
40. At the time of the collision, Defendant violated WYO. STAT. ANN. § [31-5-XXXX] by [specific violation].
41. Said statute was enacted to protect the class of persons including Plaintiff from the type of harm sustained.
42. Defendant’s statutory violation constitutes negligence per se.
    43.–45. [Damages allegations reincorporated.]

COUNT III – VICARIOUS LIABILITY / RESPONDEAT SUPERIOR (OPTIONAL)

46. Plaintiff realleges ¶¶ 1–45.
47. Defendant Driver acted within the course and scope of employment with Defendant Owner.
48. Under the doctrine of respondeat superior, Defendant Owner is vicariously liable for Driver’s negligence.
    49.–52. [Additional agency / negligent entrustment allegations.]

6. DAMAGES

53. Economic Damages: past and future medical expenses, lost wages, lost earning capacity, out-of-pocket costs, property loss.
54. Non-Economic Damages: pain and suffering, mental anguish, disfigurement, loss of enjoyment of life, and inconvenience.
55. Plaintiff seeks pre- and post-judgment interest as allowed by law.
56. Plaintiff seeks costs of suit and such further relief deemed just.
57. Pursuant to WYO. STAT. ANN. § 1-1-109, damages shall be reduced, if at all, only by Plaintiff’s comparative fault percentage.

7. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests this Court enter judgment in favor of Plaintiff and against Defendants, jointly and severally, for:

a. General and special damages in an amount to be determined by the trier of fact;
b. Pre- and post-judgment interest as provided by law;
c. Costs of suit pursuant to W.R.C.P. 54(d);
d. Such other and further relief as the Court deems just and proper.

8. JURY DEMAND

58. Pursuant to W.R.C.P. 38(b), Plaintiff demands a trial by jury on all issues so triable.

9. VERIFICATION & RULE 11 CERTIFICATION (OPTIONAL)

59. I, [ATTORNEY NAME], certify under W.R.C.P. 11 that to the best of my knowledge, information, and belief, formed after an inquiry reasonable under the circumstances, the claims and legal contentions herein are warranted by existing law and the factual contentions have evidentiary support.
    [PLAINTIFF] may additionally verify facts per W.R.C.P. 11(b)-(c).

10. CERTIFICATE OF SERVICE

60. I hereby certify that on [DATE], a true and correct copy of the foregoing Complaint was served upon the following by [method of service] pursuant to W.R.C.P. 5:
    [OPPOSING COUNSEL / DEFENDANT ADDRESS LIST]

Respectfully submitted,

[ATTORNEY NAME], WSB #__
[FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
ATTORNEY FOR PLAINTIFF

[// GUIDANCE:
• Evaluate potential comparative-fault evidence early; plead anticipatory defenses to reduce motion-practice risk.
• Consider adding spoliation-of-evidence notice or preservation order request if vehicle data/event-data recorder evidence is critical.
• Wyoming has no statutory cap on auto-accident damages; avoid language suggesting limitation.
• Confirm insurance-coverage discovery strategy; plead bad-faith reserve if insurer later becomes a party.
• If federal diversity jurisdiction is possible, preserve state-court preference via explicit forum-selection allegation and prompt service.]