Libretti v. State, 278 P.3d 234

State filed a verified forfeiture in rem for $116,584.48, five conveyances, and one firearm under Wyoming CS Act.
Libretti and Hohlios, named as claimants, answered with motions to dismiss or for a more definite statement.
Hearing on the forfeiture occurred August 10, 2011; Libretti appeared by telephone and objected to an evidentiary hearing.
Court conducted an evidentiary hearing; two DCI agents testified and Libretti testified.
District court issued a forfeiture order finding funds/properties were proceeds of violations and forfeitable; notice of appeal filed.
On appeal, court addressed Rule 12 motions, motions for more definite statement, jury trial rights, and plain-error challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing on the merits proceeded before ruling on Rule 12 motions	Libretti/Hoilios argued court erred by not ruling on motions first.	State contends hearing before ruling was permissible under Rule 12.	No error; hearing could proceed and motions later were resolvable.
Whether the district court abused its discretion denying a more definite statement	Libretti/Hoilios claimed vague pleading required more specificity.	State argues complaint provided notice and discovery could supplement.	No abuse; notice pleading satisfied and discovery could fill gaps.
Whether Libretti/Hoilios were denied a jury trial	Right to jury trial existed and was denied.	No timely jury demand; bench trial conducted with no error.	Waiver of jury demand; bench trial proper; no plain error.
Whether Hohlios was denied the right to be heard at trial	Hohlios present and denied opportunity to participate.	Record shows lack of notice to court of presence; no denial of hearing.	No plain error; absence of notice to court undermines claim.

Six v. State, 2008 WY 42 (Wy. 2008) (de novo review for legal questions in procedural rules)
BB v. RSR, 2007 WY 4 (Wy. 2007) (notice pleading; issues via deposition-discovery process)
Mead v. Leo Sheep Co., 32 Wyo. 313 (Wy. 1925) (standard for motions for a more definite statement)
Rathbun v. State, 2011 WY 116 (Wy. 2011) (plain error standard on new issues raised on appeal)
Jealous v. State, 2011 WY 171 (Wy. 2011) (plain error requirements and prejudice considerations)
Pendleton v. State, 2008 WY 36 (Wy. 2008) (plain-error prejudice analysis)
Wilson v. Lucerne Canal & Power Co., 2008 WY 126 (Wy. 2008) (abuse-of-discretion standard and discretionary review)
Doles v. State, 2007 WY 119 (Wy. 2007) (civil vs. criminal forfeiture distinction)