Kattie Boline v. Jkc Trucking, an Illinois Corporation, and Jerzy Syrzyna
2025 WY 27
Wyo.2025Background
- Kattie Boline sued JKC Trucking and driver Jerzy Syrzyna for negligence after sustaining injuries in a car accident involving a tractor-trailer on I-80 in Wyoming.
- Before trial, the parties stipulated to an order in limine excluding mention of insurance coverage.
- During her testimony at trial, Boline referenced insurance, violating the order. The court declared a mistrial, finding her conduct intentional.
- The district court sanctioned Boline, awarding $62,074.95 in attorneys’ fees and costs to JKC, and ruled no new trial would occur until the sanction was paid.
- After Boline failed to pay within several extensions, the court dismissed her case with prejudice and entered judgment for the sanction amount.
- Boline appealed, arguing the sanction and dismissal were an abuse of discretion and violated her constitutional right of court access.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Abuse of discretion in sanction and case dismissal | Sanction unreasonable; court failed to consider her mental health, financial status, and the high costs; dismissal was a "double sanction" | Sanction appropriate for intentional violation, costs were reasonable, dismissal proper for non-compliance | District court did not abuse discretion; sanction and dismissal affirmed |
| Violation of right to court access (WY Constitution, Art. I Sec. 8) | Sanction size and inability to pay denied meaningful access to courts | Court has authority to enforce orders and punish disruptions; dismissal for non-payment not a constitutional violation | No constitutional violation; plaintiff received access through initial trial |
Key Cases Cited
- Terry v. Sweeney, 10 P.3d 554 (Wyo. 2000) (upholding sanctions and dismissal as consequences for violation of court order; distinguishes between access to court and right to redress)
- Dollarhide v. Bancroft, 239 P.3d 1168 (Wyo. 2010) (explains broad trial court discretion with respect to mistrials and sanctions)
- Mills v. Reynolds, 837 P.2d 48 (Wyo. 1992) (court access as fundamental right under WY Constitution, but not absolute)
- White v. State ex rel. Wyoming Dep’t of Transp., 210 P.3d 1096 (Wyo. 2009) (no open courts violation where hearings or new trials conditioned on payment of sanctions)