**STATE OF WYOMING
[___] JUDICIAL DISTRICT COURT
COUNTY OF [COUNTY]**
[PLAINTIFF NAME],
Plaintiff,
v.
[DEFENDANT NAME],
Defendant.
Civil Action No. _______
COMPLAINT FOR PERSONAL INJURY (NEGLIGENCE)
[// GUIDANCE: Insert case caption exactly as required by Wyo. R. Civ. P. 10(a).]
TABLE OF CONTENTS
- Parties, Jurisdiction, and Venue
- Factual Allegations
- Cause of Action – Negligence
- Damages
- Reservation of Comparative Fault Re-Apportionment
- Prayer for Relief
- Demand for Jury Trial
- Verification
- Certificate of Service
[// GUIDANCE: TOC is optional under state rules but aids practitioner navigation.]
1. PARTIES, JURISDICTION, AND VENUE
1.1 Plaintiff. [PLAINTIFF NAME] (“Plaintiff”) is an individual and resident of the State of Wyoming, residing at [ADDRESS].
1.2 Defendant. [DEFENDANT NAME] (“Defendant”) is a [corporation/LLC/individual] organized under the laws of [STATE] with its principal place of business at [ADDRESS] and may be served through its registered agent, [REGISTERED AGENT], at [SERVICE ADDRESS].
1.3 Jurisdiction. This Court has subject-matter jurisdiction pursuant to Article 5, § 10 of the Wyoming Constitution and Wyo. R. Civ. P. 3 because this is a civil action for damages exceeding the jurisdictional minimum.
1.4 Venue. Venue is proper in this County under applicable Wyoming venue statutes because (a) Defendant resides, has its principal place of business, or may be served here, and/or (b) the acts and omissions giving rise to this cause of action occurred in this County.
[// GUIDANCE: If governmental entities are involved, add statutory notice-of-claim compliance allegations.]
2. FACTUAL ALLEGATIONS
2.1 On or about [DATE OF INCIDENT], at approximately [TIME], Plaintiff was lawfully present at [LOCATION].
2.2 At that time and place, Defendant, by and through its agents and employees acting within the scope of their employment, [briefly describe negligent act/omission—e.g., “failed to maintain safe premises,” “operated a motor vehicle negligently,” etc.].
2.3 Defendant owed Plaintiff a duty to exercise reasonable care under the circumstances then and there existing.
2.4 Defendant breached that duty by [specific breaches].
2.5 As a direct and proximate result of Defendant’s breach, Plaintiff suffered severe and lasting bodily injuries, including but not limited to [describe injuries], has incurred medical expenses in excess of [$___] to date, and will continue to incur such expenses in the future.
2.6 Plaintiff has additionally suffered lost wages, diminished earning capacity, pain and suffering, emotional distress, loss of enjoyment of life, and other general and special damages.
3. CAUSE OF ACTION – NEGLIGENCE
3.1 Plaintiff realleges and incorporates by reference Paragraphs 1.1 through 2.6 as though fully set forth herein.
3.2 Under Wyoming’s ordinary negligence standard, a defendant is liable when (a) a legal duty is owed, (b) that duty is breached, (c) the breach is the factual and legal cause of injury, and (d) damages result.
3.3 Defendant’s conduct, as described above, constitutes negligence per se and/or common-law negligence.
3.4 Plaintiff’s injuries and damages were the foreseeable and natural consequence of Defendant’s breaches.
3.5 Accordingly, Plaintiff is entitled to recover all legally compensable damages in an amount to be proven at trial.
4. DAMAGES
4.1 Economic Damages. Past and future medical expenses, rehabilitative costs, lost wages, and loss of future earning capacity, all in amounts presently estimated to exceed [$___], subject to proof.
4.2 Non-Economic Damages. Past and future pain and suffering, emotional distress, mental anguish, loss of enjoyment of life, and other general damages, in an amount the jury deems just and equitable.
4.3 Punitive/Exemplary Damages. To the extent allowed by Wyoming law and the evidence adduced, Plaintiff reserves the right to seek punitive damages upon proper motion and Court order.
4.4 Pre- and Post-Judgment Interest. As allowed by law.
4.5 Costs. All taxable costs pursuant to Wyo. R. Civ. P. 54(d) and Wyo. Stat. § 1-14-102.
[// GUIDANCE: Wyoming imposes no general statutory cap on personal-injury damages except in certain medical-malpractice contexts. Insert med-mal cap language if applicable.]
5. RESERVATION OF COMPARATIVE FAULT RE-APPORTIONMENT
5.1 Wyoming follows a modified comparative fault regime under which Plaintiff’s recovery is barred only if Plaintiff’s fault exceeds fifty percent (50%). Plaintiff’s recovery, if any, must be diminished by the percentage of causal fault, if any, attributed to Plaintiff.
5.2 To the extent multiple defendants acted jointly, concurrently, or in concert so that their conduct produced a single, indivisible injury, Plaintiff reserves the right to pursue joint and several liability or unified judgment to the fullest extent permitted by Wyoming law.
[// GUIDANCE: Comparative fault and proportionate liability language guards against allocation pitfalls while preserving joint-tortfeasor theories.]
6. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays for judgment against Defendant as follows:
A. For economic damages in an amount to be determined at trial;
B. For non-economic damages in an amount to be determined at trial;
C. For punitive damages as the evidence may warrant and the Court permits;
D. For pre- and post-judgment interest as allowed by law;
E. For taxable costs pursuant to rule and statute;
F. For such other and further relief, whether legal or equitable, that the Court deems just and proper.
7. DEMAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury on all issues so triable as a matter of right pursuant to Article 1, § 9 of the Wyoming Constitution and Wyo. R. Civ. P. 38.
8. VERIFICATION
I, [PLAINTIFF NAME], being first duly sworn, depose and state that I have read the foregoing Complaint, know the contents thereof, and that the same is true to the best of my knowledge, information, and belief.
[PLAINTIFF NAME]
Subscribed and sworn before me on this ___ day of _, 20.
Notary Public
My Commission Expires: ____
[// GUIDANCE: Many Wyoming judges strongly prefer or require verification in personal-injury pleadings—confirm local practice.]
9. CERTIFICATE OF SERVICE
I certify that on this ___ day of _, 20, I served a true and correct copy of the foregoing Complaint upon the following counsel of record by [state means of service consistent with Wyo. R. Civ. P. 5]:
• [OPPOSING COUNSEL NAME & ADDRESS]
[ATTORNEY NAME], Wyo. Bar No. [____]
[LAW FIRM NAME]
[ADDRESS]
[PHONE] | [EMAIL]
Attorney for Plaintiff
[// GUIDANCE:
1. Review local district-court rules for any additional pleading, discovery-plan, or scheduling-order requirements.
2. Update all placeholders—dates, names, dollar figures, statutory references, venue facts—before filing.
3. Evaluate whether a Governmental Claims Act notice, healthcare screening panel affidavit, or similar prerequisite applies.
4. If punitive damages are pursued, file a motion under Wyo. Stat. § 1-1-109 to amend pleadings once a prima facie case is established.]