LS v. JEQ (In re Mears), 426 P.3d 824

Father and Mother agreed that Father would consent to an adoption in exchange for Mother waiving past and future child support; Father performed and the adoption was finalized in July 2016.
Disputes arose over a release of arrearages; Father filed a Motion to Enforce Settlement after delays and correspondence between counsel.
The district court enforced the settlement, awarded Father $4,903.50 in attorney fees against Mother, and later found Mother’s counsel, Traci E. Mears, violated W.R.C.P. 11(b) and imposed an identical sanction against Ms. Mears, joint and several with Mother’s judgment.
A Notice of Satisfaction indicated Mother and Ms. Mears each paid half of the judgment; Mother (LS) then filed an appeal titled as her appeal but explicitly stating it was appealing the order imposing sanctions on Ms. Mears.
The Supreme Court considered whether it had subject matter jurisdiction because the sanctions were imposed only on the attorney and the appeal was filed in the client’s name rather than the attorney’s.
The Court concluded Ms. Mears did not file a timely notice of appeal in her own name and, under Wyoming precedent, clients lack standing to appeal sanctions against their attorneys; the appeal was dismissed for lack of jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred imposing W.R.C.P. 11 sanctions on Ms. Mears	Mother (LS) challenged the sanction order as erroneous	Father contended the appeal lacks jurisdiction because only the attorney may appeal sanctions imposed on her	Dismissed for lack of jurisdiction; substantive challenge not reached
Whether Wyoming Supreme Court has jurisdiction to hear an appeal of sanctions imposed on an attorney when the appeal was filed in the client’s name	Ms. Mears (via Mother’s notice) argued the caption and notice sufficed and the Court should hear the appeal; invoked a prior narrow exception	Father argued clients lack standing to appeal sanctions against their attorneys and the sanctioned attorney must file a timely notice of appeal in her own name	Held that only the sanctioned attorney may appeal; the Court overruled the Caldwell exception and dismissed for lack of jurisdiction

Welch v. Hat Six Homes, 47 P.3d 199 (Wyo. 2002) (an appeal of sanctions against an attorney must be filed in the attorney’s name; client lacks standing)
Goglio v. Star Valley Ranch Ass'n, 48 P.3d 1072 (Wyo. 2002) (reaffirming Welch that the attorney must appeal in his/her own name)
Caldwell v. Cummings, 33 P.3d 1138 (Wyo. 2001) (earlier caption amendment where the Court had allowed substitution, discussed as a narrow exception)
Laurino v. Tate, 220 F.3d 1213 (10th Cir. 2000) (federal case cited regarding when a notice may imply an attorney’s intent to appeal)
Estate of Bishop v. Bechtel Power Corp., 905 F.2d 1272 (9th Cir. 1990) (client lacks the requisite interest to appeal sanctions imposed on an attorney)
Edsall v. Moore, 375 P.3d 799 (Wyo. 2016) (jurisdictional issues are questions of law reviewable de novo)