In the Interest of NP, a minor child. CP v. State, 2017 WY 18

NP, a 17-year-old with Asperger’s and other diagnoses, left swim practice on December 14, 2015 wearing only swim trunks during a snowstorm.
Police found NP at school, clothed him with donated garments, and returned him to his home; Mother was verbally abusive to officers and refused to allow them inside or to discuss options.
Officer Bullard took NP into protective custody and placed him at the Youth Crisis Center (YCC) after being unable to reach Mother or obtain cooperation.
The State filed a neglect petition; at the initial hearing the juvenile court advised Mother she could demand a jury trial within ten days and appointed counsel.
Mother did not file a written jury demand within the statutory ten-day period; she later claimed she had phoned the clerk and judge’s secretary to request a jury trial and filed a Motion for Jury Trial after the deadline.
The juvenile court denied the late jury-demand motion, adjudicated NP neglected, and Mother appealed challenging waiver of jury trial and sufficiency of evidence.

Issue	Mother’s Argument	State’s Argument	Held
Whether Mother waived jury right by failing to timely file demand	Mother: oral/phone requests to clerk and judge’s secretary within ten days preserved the right	State: statutory ten-day demand must follow Rule 38 filing requirements; failure to file waives right	Held: Waiver — demand must be written, filed, and served under Rule 38; phone calls insufficient
Whether evidence sufficed to adjudicate neglect	Mother: NP was safe with police/YCC and she expected NP to be taken there; incident was an isolated parenting lapse	State: Mother left NP in cold without adequate clothing, refused custody/communication, and did not arrange alternatives	Held: Sufficient evidence — Mother failed to provide adequate care/supervision and refused return/communication, supporting neglect finding

In re CRA, 2016 WY 24, 368 P.3d 294 (Wy. 2016) (de novo review for statutory/constitutional questions)
In re MN, 2007 WY 189, 171 P.3d 1077 (Wy. 2007) (rules of statutory interpretation)
In re GC, 2015 WY 73, 351 P.3d 236 (Wy. 2015) (standards for sufficiency of evidence in juvenile adjudications)
In re MC, 2013 WY 43, 299 P.3d 75 (Wy. 2013) (appellate review deferential to trial court credibility findings)
In re "H" Children, 2003 WY 155, 79 P.3d 997 (Wy. 2003) (preponderance standard and review approach in neglect cases)
In re Patel, 2010 WY 147, 242 P.3d 1015 (Wy. 2010) (apply more specific statute over general rule)
Olsen v. State, 2003 WY 46, 67 P.3d 536 (Wy. 2003) (precedence to specific statutory provisions)
Wrecking Corp. of Am., Inc. v. Jersey Welding Supply, Inc., 463 A.2d 678 (D.C. 1983) (applying civil rules where statute silent on procedural details)