Hodson v. Sturgeon, 2017 WY 150

Hodson sued Sturgeon for breach of contract, dissolution of partnership, and claimed entitlement to jointly owned property.
On the day of trial the parties announced a settlement, recited its terms on the record, and filed a written settlement agreement signed by both parties.
The district court entered an order adopting the settlement; Hodson timely appealed pro se.
Hodson’s appellate brief failed to comply with Wyo. R. App. P. requirements: no record-designation, inadequate record citations, omitted the appealed order, and included exhibits not in the record.
His brief lacked cogent legal argument and citations to authority; the court found the issues raised unclear and unsupported.
The Wyoming Supreme Court summarily affirmed the district court’s order and directed Sturgeon to submit a statement of attorney fees and costs for an award.

Issue	Hodson's Argument	Sturgeon’s Argument	Held
Whether the district court erred by adopting the parties’ settlement	Hodson asserts a prior agreement should have been enforced instead of the court-accepted settlement	Settlement was valid; district court properly adopted it	Affirmed — court adopted the settlement; Hodson failed to meaningfully challenge it
Whether appellant complied with appellate procedural rules	Hodson did not designate record portions or provide required citations; contends errors but gives few record citations	Sturgeon contends Hodson failed to follow W.R.A.P. and thus the appeal is deficient	Held noncompliance with W.R.A.P.; summary affirmance appropriate
Whether the brief presented cogent legal argument and authority	Hodson made unclear assertions but provided no cogent legal support or authorities	Sturgeon argued there is no cogent argument or pertinent authority to support the appeal	Held brief lacked cogent argument and authority; appellate review declined
Whether appellee is entitled to attorney fees and costs for frivolous appeal	Hodson did not argue reasonableness of appeal; offered no authority	Sturgeon sought fees under W.R.A.P. 10.06 given lack of reasonable cause	Court certified no reasonable cause and directed Sturgeon to submit fee statement for award

Hodgins v. State, 1 P.3d 1259 (Wyo. 2000) (pro se litigants entitled to leniency but must reasonably adhere to procedural rules)
Young v. State, 46 P.3d 295 (Wyo. 2002) (affirming that pro se parties must follow appellate rules; sanctions may include summary affirmance)
Basolo v. Gose, 994 P.2d 968 (Wyo. 2000) (appeals lacking cogent argument and pertinent authority may be dismissed)
Marshall v. State, 385 P.3d 304 (Wyo. 2016) (court may decline to consider unsupported claims)
DeLoge v. State, 289 P.3d 776 (Wyo. 2012) (quoting discretion to disregard unsupported arguments)
Grynberg v. L & R Exploration Venture, 261 P.3d 731 (Wyo. 2011) (reluctance to impose Rule 10.06 sanctions but permissible when appeal lacks merit)
Amen, Inc. v. Barnard, 938 P.2d 866 (Wyo. 1997) (discussing standards for awarding appellate sanctions)