Bruce B. Williams v. Laura L. Sundstrom, as Campbell County Coroner
2016 WY 122
| Wyo. | 2016Background
- Nikki Jo Burtsfield was fatally shot by law enforcement; the Campbell County Coroner examined the body and prepared an official verdict and docket listing manner as homicide and a detailed cause of death (exsanguination due to multiple gunshot wounds with organ perforations).
- Appellant Bruce B. Williams requested the coroner’s verdict and docket under Wyoming public records law; deputies, who could not access the coroner’s locked file, produced a simplified substitute listing "2 gunshot wounds to torso."
- Williams sued in district court via a pro se "Motion for Reasonable Response," asking the court to order the coroner to produce a more detailed docket sufficient for public evaluation of government performance.
- The county moved to dismiss or, alternatively, for summary judgment, and submitted the coroner’s actual (more detailed) verdict and affidavits; the district court entered judgment on the pleadings (but in effect granted summary judgment) for the coroner.
- The Supreme Court of Wyoming treated Williams’ filing as a mandamus action (despite pleading defects), addressed the merits, and affirmed summary judgment for the coroner, holding the coroner’s report met statutory requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Williams invoke district court jurisdiction with his "Motion for Reasonable Response"? | Williams filed a pro se motion seeking court order; argued relief should be granted. | County argued the action was improper procedurally and should be dismissed. | Court treated the filing as a mandamus petition despite pleading defects and exercised jurisdiction. |
| Did the coroner have a clear statutory duty to provide the greater level of detail Williams demanded in the verdict/docket? | Williams argued statute required more detailed description (bullet trajectories, pathways, diagrams) to evaluate government performance. | Coroner argued statute only requires listing cause and manner of death and other basic facts; her verdict/docket satisfied that duty. | Court held statute requires cause and manner of death but not the extra detail Williams sought; coroner fulfilled statutory duty. |
| Was the district court’s procedural ruling appropriate given the materials considered? | Williams objected to motion basis but did not dispute consideration of extra-pleading materials. | County relied on affidavits and the coroner’s actual docket supporting summary judgment. | Court concluded the district court’s Rule 12(c) label was incorrect but that it effectively granted summary judgment after considering affidavits; review de novo affirmed judgment. |
| Could mandamus issue given pleading defects and required procedures? | Williams had not followed formal mandamus pleading/statutory steps. | County noted procedural defects but urged dismissal on merits. | Court held pleading defects were not jurisdictional; could have been amended, but merits resolved and mandamus denied because no clear, ministerial duty to produce more detail. |
Key Cases Cited
- City of Casper v. Holloway, 354 P.3d 65 (Wyo. 2015) (jurisdiction may be raised at any time)
- In re AGS, 337 P.3d 470 (Wyo. 2014) (jurisdictional principles for actions in district court)
- Golden v. Guion, 375 P.3d 719 (Wyo. 2016) (de novo review for jurisdictional legal questions)
- Ridgerunner, LLC v. Meisinger, 297 P.3d 110 (Wyo. 2013) (conversion of pleadings to summary judgment when court considers affidavits)
- Inman v. Boykin, 330 P.3d 275 (Wyo. 2014) (summary judgment standards and consideration of materials outside pleadings)
- Snell v. Snell, 374 P.3d 1236 (Wyo. 2016) (standard of review for summary judgment)
- State ex rel. Arnold v. Ommen, 201 P.3d 1127 (Wyo. 2009) (mandamus issues: duty must be clear, ministerial, and nondiscretionary)
- Allendale Water & Sewer Dist. v. State ex rel. Hansuld, 919 P.2d 146 (Wyo. 1996) (summary judgment may be used in mandamus actions)