WRONGFUL TERMINATION DEMAND LETTER

Wyoming Law

[ATTORNEY/FIRM LETTERHEAD]

[Firm Name]
[Address Line 1]
[City, State ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[Wyoming State Bar No.]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND VIA EMAIL TO: [recipient_email]

[Date]

[Employer Contact Name]
[Title]
[Company Legal Name]
[Company Address]
[City, State ZIP]

Re: Wrongful Termination of [Client Full Name]
Former Position: [Job Title]
Dates of Employment: [Start Date] through [Termination Date]
CONFIDENTIAL SETTLEMENT COMMUNICATION - WYO. R. EVID. 408

Dear [Mr./Ms./Mx. Last Name]:

This firm represents [Client Full Name] ("our client") regarding [his/her/their] wrongful termination from employment with [Company Legal Name] ("[Company Short Name]") on [Termination Date]. Please direct all further communications to our office.

We write to demand immediate action to remedy the unlawful termination and to resolve this matter short of litigation. [Company Short Name]'s termination of our client violates Wyoming law and exposes the Company to substantial liability.

I. WYOMING EMPLOYMENT LAW FRAMEWORK

A. At-Will Employment and Its Exceptions

Wyoming is one of the strongest at-will employment states in the nation. Wyo. Stat. 27-1-104 codifies the at-will doctrine. However, limited exceptions exist:

1. Public Policy Exception

Wyoming has recognized a very narrow public policy exception in limited circumstances. See Griess v. Consol. Freightways Corp., 776 P.2d 752 (Wyo. 1989).

The exception requires:
- Clear and compelling public policy
- Policy must be well-established in law
- Employee's conduct must directly further the policy

2. Workers' Compensation Retaliation

Wyo. Stat. 27-14-601 prohibits retaliation for exercising workers' compensation rights.

3. Wyoming Fair Employment Practices Act

Wyo. Stat. 27-9-101 et seq. provides limited protection against employment discrimination.

B. Key Wyoming Statutes

Wyoming Fair Employment Practices Act (Wyo. Stat. 27-9-101 et seq.)
- Prohibits discrimination based on sex, race, creed, color, national origin, ancestry, age (40+), disability
- Covers employers with two or more employees
- 2-year statute of limitations for civil action

Workers' Compensation Retaliation (Wyo. Stat. 27-14-601)
- Prohibits discharge for filing workers' compensation claims
- Provides for civil action

Whistleblower Protection (Wyo. Stat. 9-11-103)
- Protects state employees who report violations of law
- Limited to public sector

Note: Wyoming is a non-deferral state for EEOC purposes - 180-day deadline applies.

II. FACTUAL BACKGROUND

A. Employment History

[Client Full Name] was employed by [Company Short Name] from [Start Date] through [Termination Date] as a [Job Title] in [City], Wyoming.

Employment Summary:

Our client was a dedicated employee with an excellent performance record:
- [Describe positive performance history]
- [Describe promotions, raises, commendations]
- [Describe any relevant achievements]

B. The Protected Activity / Triggering Event

On or about [Date], our client [describe protected activity]:

• Refused to violate Wyoming or federal law by [describe illegal act requested]
• Filed a workers' compensation claim under Wyo. Stat. 27-14-601
• Reported violations of law affecting public safety
• Exercised rights under [specific statute]
• [Other protected activity]

C. The Wrongful Termination

On [Termination Date], [Company Short Name] terminated our client, purportedly for [stated reason]. This stated reason is pretextual, as evidenced by:

1. Temporal proximity: The termination occurred just [X days/weeks] after the protected activity
2. Prior positive treatment: Our client had [no prior discipline / positive reviews / recent promotion]
3. Disparate treatment: Similarly situated employees who did not engage in protected activity were [not terminated / treated more favorably]
4. Shifting explanations: [Describe any inconsistent reasons given]
5. Direct evidence: [Describe any statements indicating true motive]

III. LEGAL CLAIMS UNDER WYOMING LAW

A. Wrongful Termination in Violation of Public Policy

[Company Short Name] terminated our client in violation of Wyoming's public policy against [describe the public policy violated]:

Source of Public Policy: [Cite Wyoming statute, constitutional provision, or court decision]

While Wyoming maintains a strong at-will doctrine, the Wyoming Supreme Court has recognized that termination may be actionable when it violates clear public policy. See Griess v. Consol. Freightways Corp., 776 P.2d 752 (Wyo. 1989).

Elements required:
1. Clear and compelling public policy exists
2. The policy is well-established in Wyoming law
3. Employee's conduct directly furthered the policy
4. Termination was in retaliation for that conduct

See also Allen v. Safeway Stores, Inc., 699 P.2d 277 (Wyo. 1985).

B. Retaliatory Discharge - Workers' Compensation (Wyo. Stat. 27-14-601)

[If applicable:] Wyoming Statutes 27-14-601 prohibits employers from discharging employees for exercising workers' compensation rights.

Our client filed a workers' compensation claim on [Date] for [injury]. [Company Short Name] terminated our client in retaliation.

Remedies:
- Actual damages
- Reinstatement
- Back pay and benefits
- Attorney's fees and costs

C. Violation of Wyoming Fair Employment Practices Act (Wyo. Stat. 27-9-101 et seq.)

[If applicable:] [Company Short Name]'s termination was motivated by discrimination based on [protected characteristic].

WFEPA prohibits employment discrimination based on sex, race, creed, color, national origin, ancestry, age (40+), and disability.

Remedies under WFEPA:
- Actual damages
- Reinstatement
- Back pay
- Injunctive relief

D. Breach of Express Contract

[If applicable:] [Company Short Name] breached an express employment contract.

Evidence of contract:
- Written employment agreement stating [quote relevant language]
- Specific term of employment
- Express limitations on termination

Note: Wyoming courts do not generally recognize implied contracts from employee handbooks. See Wyo. Stat. 27-1-108.

IV. DAMAGES

A. Economic Damages

1. Back Pay

2. Lost Benefits

3. Front Pay

B. Compensatory Damages (Non-Economic)

Our client has suffered severe emotional distress:
- [Describe anxiety, depression, humiliation]
- [Describe impact on health and relationships]
- [Describe medical treatment sought]

Emotional distress damages: $[Amount]

C. Punitive Damages

[Company Short Name]'s conduct was willful, malicious, and in conscious disregard of our client's rights.

Punitive damages: $[Amount]

D. Attorney's Fees

Under applicable Wyoming statutes, our client may be entitled to reasonable attorney's fees.

Estimated fees through trial: $[Amount]

E. Summary of Damages

V. SETTLEMENT DEMAND

We demand that [Company Short Name] pay $[Settlement Demand Amount] in full settlement of all claims.

Additional Terms:
- Neutral reference (dates and position only)
- No contest to unemployment benefits
- Expungement of personnel file
- Mutual non-disparagement
- Confidentiality (terms to be negotiated)

VI. RESPONSE DEADLINE

Please respond within fourteen (14) calendar days, no later than [Response Deadline Date].

If we do not receive a satisfactory response, we are authorized to file suit in the [District Court of [County] County, Wyoming / United States District Court for the District of Wyoming] without further notice.

Causes of Action:
1. Wrongful Termination in Violation of Public Policy
2. Retaliatory Discharge in Violation of Wyo. Stat. 27-14-601
3. Violation of Wyoming Fair Employment Practices Act (Wyo. Stat. 27-9-101 et seq.)
4. Breach of Express Contract
5. [Other claims as applicable]

VII. DOCUMENT PRESERVATION

Immediately implement a litigation hold to preserve all relevant documents and ESI regarding our client's employment, performance, and termination.

VIII. CONFIDENTIALITY

This letter is protected by Wyoming Rule of Evidence 408 and constitutes a confidential settlement communication.

Sincerely,

[Attorney Name]
[Title]
[Firm Name]
[Wyoming State Bar No.]

Enclosures:
- Authorization to Represent

cc: [Client Name]
[File]

WYOMING-SPECIFIC PRACTICE NOTES (Do Not Include in Final Letter)

Key Wyoming Considerations

• Wyoming is one of the strongest at-will employment states in the nation
• Wyo. Stat. 27-1-104 codifies at-will doctrine
• Wyo. Stat. 27-1-108 expressly disclaims implied contracts from handbooks
• Public policy exception is extremely narrow - requires clear statutory/constitutional basis
• Wyoming is a NON-DEFERRAL state - 180-day EEOC deadline
• No state fair employment practices agency for private sector
• WFEPA covers employers with 2+ employees
• Workers' compensation retaliation is the strongest statutory claim
• Consider federal claims (Title VII, ADA, ADEA) for discrimination cases
• Wyoming does not have a comprehensive state civil rights enforcement agency
• Whistleblower statute limited to state employees

Venue Options

• Wyoming District Court (general jurisdiction)
• Federal Court (if federal claims or diversity jurisdiction)
• Wyoming does not have a state FEP agency like most states

Statute of Limitations

Key Wyoming Cases

• Griess v. Consol. Freightways Corp., 776 P.2d 752 (Wyo. 1989) (public policy exception)
• Allen v. Safeway Stores, Inc., 699 P.2d 277 (Wyo. 1985) (at-will doctrine)
• Wilder v. Cody Country Chamber of Commerce, 868 P.2d 211 (Wyo. 1994) (at-will employment)
• Leithead v. Am. Colloid Co., 721 P.2d 1059 (Wyo. 1986) (implied contract)
• Bear v. Volunteers of Am., Wyo., 964 P.2d 1245 (Wyo. 1998) (wrongful discharge)