State of Wyoming ex rel. West Park Hospital District and Yellowstone Behavioral Health Center v. Bryan A. Skoric, Park County and Prosecuting Attorney, In His Official Capacity, 2014 WY 41

Appellants West Park Hospital District and Yellowstone Behavioral Health Center sought mandamus to compel Park County Attorney Skoric to participate in emergency detention and involuntary hospitalization proceedings under Wyo. Stat. Ann. §§ 25-10-109, 25-10-110.
Historically, the Park County Attorney’s office filed and prosecuted involuntary hospitalization cases, including opening and closing, direct and cross examinations, and handling paperwork.
In 2013, following In re RB, Skoric reconsidered his office’s role, concluding he had no authority to participate in emergency detention hearings and that appearing at § 110 hearings did not require presenting the case in chief.
Appellants filed a verified petition for a writ of mandamus, arguing the statutes require the county attorney to commence and present the case in these proceedings.
The district court denied the petition, citing ambiguity in §§ 25-10-109 and 110 and relying on In re RB, and the matter was appealed to the Wyoming Supreme Court.
The Wyoming Supreme Court ultimately held the statutes are ambiguous, concluded the county attorney has a duty to commence involuntary hospitalization proceedings and to appear and present the State’s case, but nonetheless affirmed the district court’s denial of mandamus at the time because the duty was not clearly and indisputably defined when mandamus was sought.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Do §§ 25-10-109 and 25-10-110 impose a duty on the county attorney in civil commitment proceedings?	Appellants argue the statutes require the county attorney to participate and present the case.	Skoric contends the statutes do not clearly define such a duty or require participation in all stages.	Yes, statutes are ambiguous; county attorney has some duty but not a clear, ministerial obligation yet.
Was the district court's denial of mandamus appropriate given the statutory ambiguity?	Appellants claim mandamus was proper to compel a clearly defined duty.	Skoric contends mandamus is improper where the duty is not clear and indisputable.	No mandamus warranted at that time; district court did not abuse discretion.

In re RB, 294 P.3d 24 (Wyo. 2013) (duty of county attorney in involuntary hospitalization proceedings examined)
Arnold v. Ommen, 201 P.3d 1127 (Wyo. 2009) (mandamus standards; ministerial duty requirements)
McTiernan v. Jellis, 316 P.3d 1153 (Wyo. 2013) (statutory interpretation; avoid absurd results)
State ex rel. Epp v. Mayor, 894 P.2d 590 (Wyo. 1995) (mandamus and statutory duty principles)
Romsa v. State ex rel. Wyoming Dep’t of Transp., 288 P.3d 695 (Wyo. 2012) (ambiguity and statutory interpretation principles)
K N Energy, Inc. v. City of Casper, 755 P.2d 207 (Wyo. 1988) (extrinsic evidence and delegation of authority principles)