Christiansen v. Christiansen, 2011 WY 90

Paula Christiansen and Victoria Christiansen, residents of Wyoming, were validly married in Canada in 2008.
Paula filed for divorce in Wyoming in February 2010 seeking dissolution of the Canadian marriage.
The district court dismissed for lack of subject-matter jurisdiction, relying on Wyoming's definition of marriage as male-female.
Wyoming recognizes foreign marriages under § 20-1-111, but the district court treated the Canadian marriage as non-existent for dissolution purposes.
The Wyoming Supreme Court held the district court has subject-matter jurisdiction to entertain the divorce and remanded for proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wyoming district court has jurisdiction to dissolve a same-sex marriage valid where solemnized	Christiansen: jurisdiction exists despite same-sex status since marriage validity abroad is recognized for divorce.	Christiansen: § 20-1-101 defines marriage as male-female; no marriage to dissolve.	Yes; district court has jurisdiction.

Granite Springs Retreat Ass'n, Inc. v. Manning, 133 P.3d 1005 (Wy. 2006) (subject-matter jurisdiction; de novo standard)
State Farm Mut. Auto. Ins. Co. v. Kunz, 186 P.3d 378 (Wy. 2008) (subject-matter jurisdiction; authority to proceed)
Brown v. City of Casper, 248 P.3d 1136 (Wy. 2011) (de novo review; interpretation of statutes)
Jessen v. Burry, 13 P.3d 1118 (Wy. 2000) (statutory construction; harmony of related laws)
Billis v. State, 800 P.2d 401 (Wy. 1990) (harmonization of statutes; avoid nullification)
Hoagland v. Hoagland, 193 P. at 843-44 (Wy. 1920) (lex loci celebrationis; recognition of foreign marriages)
Bowers v. Wyoming State Treasurer, 593 P.2d 182 (Wy. 1979) (recognition of foreign marriages; policy exceptions)
Jim's Water Serv. v. Eayrs, 590 P.2d 1346 (Wy. 1979) (foreign marriage validity for workers' compensation)
In re Roberts' Estate, 58 Wyo. 438 (Wy. 1943) (validity of common-law marriages founded abroad for limited purposes)