Bret Vance v. Wyomed Laboratory, Inc. and Georgia L. Carmen, 375 P.3d 746

Wyomed conducted a breath test on Vance on December 5, 2012 showing BAC 0.016% and notified the City and Vance the same day.
Vance was terminated from employment based on the December 5, 2012 test result.
At a February 12, 2013 administrative hearing, Vance became aware of facts suggesting improper maintenance of the breathalyzer.
Vance filed a claim on May 18, 2015 under the Wyoming Medical Review Panel Act and later sued Wyomed for negligence and related claims.
Wyomed moved to dismiss under Rule 12(b)(6), arguing the two-year statute of limitations in § 1-3-107(a) had run.
The district court granted the motion and the Supreme Court affirmed, holding all acts giving rise to the claims occurred on December 5, 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Vance's claims barred by § 1-3-107(a)?	Discovery within one year tolled limitations under discovery rule.	All acts occurred on December 5, 2012; claims filed after two years are untimely.	Yes; claims barred under § 1-3-107(a).

Feltner v. Casey Family Program, 902 P.2d 206 (Wy. 1995) (statute of limitations with discovery rules standard)
Trinity St. John v. Wagner, 302 P.3d 906 (Wy. 2013) (de novo review of statute-of-limitations questions)
Mummery v. Polk, 770 P.2d 241 (Wy. 1989) (testing sufficiency of complaints under dismissal standard)
Sump v. Sheridan, 358 P.2d 637 (Wy. 1961) (undisputed dates in limitations context)
Nobles v. Memorial Hosp. of Laramie County, 301 P.3d 517 (Wy. 2013) (continuing course of treatment rule applicability)
Errington v. Zolessi, 9 P.3d 966 (Wy. 2000) (clarifies punitive damages vs. separate cause of action)
Vroman v. Town & Country Credit Corp., 158 P.3d 141 (Wy. 2007) (distinguishes punitive damages from independent claims)