Cate Street Capital, Inc., a Delaware Corporation and Red Desert Reclamation, LLC, a Wyoming Limited Liability Company v. Automation & Electronics, Inc., 368 P.3d 302

Red Desert contracted A&E for electrical work (2012); A&E and Consolidated Electric (CE) sued for unpaid amounts and sought liens; actions were consolidated.
Red Desert entered a mortgage with CSC and later confessed judgment to A&E and CE; A&E obtained a stipulated judgment against Red Desert on June 3, 2014 (not certified under W.R.C.P. 54(b)).
A&E moved to amend its complaint to add CSC and Cate Street as defendants, alleging alter-ego and fraudulent conveyance; the court granted leave to amend and defendants answered.
CE’s claims were later dismissed without prejudice; A&E pursued discovery directed at CSC, Cate Street, and Red Desert but defendants repeatedly failed to comply.
The district court imposed sanctions for discovery noncompliance, entering default judgments that made CSC and Cate Street jointly and severally liable and set aside the CSC mortgage as fraudulent.
Defendants argued on appeal that the court lacked subject matter jurisdiction to allow A&E’s amendment after the stipulated judgment; the Wyoming Supreme Court affirmed, holding the court retained jurisdiction under W.R.C.P. 54.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court lost subject-matter jurisdiction to allow A&E to amend its complaint after entering a stipulated judgment in favor of A&E against Red Desert	A&E argued the court retained jurisdiction to allow amendment because the consolidated action still involved other claims/parties and Rule 54(b) was not invoked, so the partial judgment was not final	Defendants argued federal precedent interpreting rules like Rule 15 forbids amendment after judgment unless judgment is vacated or set aside, so the court lacked jurisdiction once the stipulated judgment was entered	The court held the district court retained subject-matter jurisdiction under W.R.C.P. 54 because the judgment on A&E’s claim was not final or appealable absent a Rule 54(b) certification; amendment was therefore permissible

Ultra Resources, Inc. v. Hartman, 346 P.3d 880 (Wyo. 2015) (standard of review for subject-matter-jurisdiction issues)
Harmon v. Star Valley Medical Center, 331 P.3d 1174 (Wyo. 2014) (failure to raise jurisdictional defects does not waive review)
Woods v. Wells Fargo Bank Wyoming, 90 P.3d 724 (Wyo. 2004) (procedural irregularities do not create or destroy subject-matter jurisdiction)
State ex rel. Frederick v. District Court, 399 P.2d 583 (Wyo. 1965) (rules cannot expand or limit subject-matter jurisdiction)
State v. Kusel, 213 P. 367 (Wyo. 1923) (court acquires procedural authority to proceed when case is initiated)
Thiele v. Security State Bank of New Salem, 396 N.W.2d 295 (N.D. 1986) (Rule 54(b) certification can make a partial judgment final)
United States v. Evans, 365 F.2d 95 (10th Cir. 1966) (partial journalized judgment without Rule 54(b) certification is not final)
Seymour v. Thornton, 79 F.3d 980 (10th Cir. 1996) (federal rule law that, after judgment, amended complaint generally impermissible absent vacatur under Rules 59/60)