362 P.3d 331
Wyo.2015Background
- Inmate JonMichael Guy requested to view the Wyoming DOC Policy & Procedure #1.215 (Code of Ethics); it was initially denied by Warden Hargett as not preapproved for inmate review.
- Guy resubmitted the request under the Wyoming Public Records Act (WPRA); Deputy Director Lindly later determined the policy was a public record and arrangements were made for Guy to view it.
- Guy pursued internal grievances seeking training for staff, discipline, and fines; internal reviewers found the matter resolved because Guy was ultimately allowed to inspect the record.
- Guy filed a petition for declaratory judgment claiming WPRA violations, seeking broad declaratory and injunctive relief (including a declaration that DOC policies are subject to WPRA, mandatory training, policy revisions, and monetary penalties).
- Defendants moved to dismiss for lack of subject-matter jurisdiction and failure to state a claim; the district court dismissed, finding the WPRA defined the sole remedies and Guy had not pursued them and had already been given access. Guy’s motion to amend (to plead under the UDJA and add injunction authority) was not ruled on expressly; the court implicitly denied it as futile.
Issues
| Issue | Guy's Argument | Lampert/Hargett's Argument | Held |
|---|---|---|---|
| Whether the district court erred by dismissing Guy's petition under WPRA/for declaratory relief | Guy contended initial denial and delayed production violated WPRA and sought declaratory/injunctive relief and penalties | WPRA prescribes specific remedies (show-cause/order to compel, written denial, petition re: delay); Guy received the record so no WPRA remedy remained; requested relief exceeds WPRA authority | Dismissal affirmed: WPRA sets exclusive remedies; no relief available where access was ultimately provided and requested relief (policy-wide declarations, training, private penalties) is beyond WPRA authority |
| Whether the court abused discretion by denying leave to amend to plead under the UDJA and add injunctive jurisdiction | Guy argued amending to invoke UDJA and injunctive statutes would cure jurisdictional defect and present a justiciable controversy | Amendment would be futile because UDJA does not expand jurisdiction beyond underlying statute, and claims sought advisory/future rulings and would not resolve an actual controversy | Denial affirmed: amendment would be futile; UDJA requires an existing justiciable controversy and cannot create jurisdiction to grant the relief Guy sought |
Key Cases Cited
- William F. West Ranch, LLC v. Tyrrell, 206 P.3d 722 (Wyo. 2009) (UDJA does not extend court jurisdiction beyond underlying statutes; requirements for declaratory relief)
- Powder River Basin Res. Council v. Wyo. Oil & Gas Conservation Comm’n, 320 P.3d 222 (Wyo. 2014) (WPRA procedures must be followed to challenge denials; statute anticipates custodian/public disagreements resolved in district court)
- Allsop v. Cheyenne Newspapers, Inc., 39 P.3d 1092 (Wyo. 2002) (WPRA defines remedies for denial of access)
- Bird v. Rozier, 948 P.2d 888 (Wyo. 1997) (court may refuse declaratory relief when judgment would not terminate uncertainty or affect parties’ legal relationships)
- Anderson v. Wyo. Dev. Co., 154 P.2d 318 (Wyo. 1944) (courts ordinarily will not decide future or contingent rights; no advisory opinions)