Mary Lankford, in her official capacity as Sublette County Clerk v. Paul Rock, Dari Quirk, & Ernest Kawa, 2013 WY 61

In 2011 Sublette County voters approved increasing county commissioners from three to five.
In 2012 a second ballot proposition passed to decrease membership from five back to three.
Clerk Lankford certified that the 2012 measure reduced the number of seats, and scheduled an election for one seat in 2012.
Appellants Rock, Quirk, and Kawa challenged Lankford’s interpretation and sought declaratory relief and mandamus.
The district court dismissed some claims, granted summary judgment to Lankford on the interpretation, and held the May 2012 election proper.
The Wyoming Supreme Court concluded the action was an election contest, which was untimely and not brought by five electors, and remanded for dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the action is an election contest under § 22-17-105	Rock asserts contested ballot proposition remedy	Lankford argues statute provides exclusive contest remedy	Yes; it is an election contest under § 22-17-105
If election contest, do requirements for standing and timing apply	Appellants claim declaratory relief is proper and time limits do not apply	Lankford maintains five electors, 15-day deadline, and jurisdictional limits apply	No; the contest requirements were not met

Johnson v. City of Cheyenne, 504 P.2d 1081 (Wyo. 1973) (strict jurisdictional requirements for election contests)
Snell v. Johnson County School District No. 1, 86 P.3d 248 (Wyo. 2004) (timing distinctions for use of election proceeds in contests)
Braun v. Borough, 193 P.3d 719 (Alaska 2008) (remedy focus; election contest scope depends on relief sought)
Mackey v. Blackwell, 834 N.E.2d 346 (Ohio 2005) (grounds for election contest are exclusive in some: relief vs. status)
Gronberg v. Teton Cnty. Housing Authority, 247 P.3d 35 (Wyo. 2011) (principles of applying conflicting statutes in context)