Steven Aron and Galen Woelk, Affiliated Attorneys At Law and Aron & Hennig, Llp, a Wyoming Limited Liability Partnership v. Spencer Willey and Ethan G. Willey and Alexus N. Willey, Minor Children, By and Through Their Next Friend, Stephanie Withrow, 453 P.3d 1031

Plaintiffs (Spencer Willey and his minor children) sued two Sheridan-area attorneys, Steve Aron and Galen Woelk, and their firm for legal malpractice in Sheridan County.
Aron & Woelk had previously represented the Willeys in Sheridan County litigation; the malpractice claim alleges loss of trust beneficiary status and over $3 million in damages.
Aron and Woelk are residents of Albany County, maintain their principal place of business there, and were served with the malpractice complaint in Albany County.
Defendants moved to dismiss for improper venue under Wyo. Stat. Ann. §§ 1-5-105 and 1-5-108; the district court denied the motion, construing § 1-5-108 as permissive and finding Sheridan County proper.
The Wyoming Supreme Court granted review, held that § 1-5-108 mandates filing where a defendant resides or is actually summoned, concluded none of the defendants were summoned in Sheridan County, reversed the district court, and ordered dismissal without prejudice for improper venue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by denying a motion to dismiss for improper venue	Sheridan County is a proper venue because § 1-5-108 is permissive and defendants could reasonably expect to be summoned there (given prior Sheridan litigation)	Venue is improper because defendants reside, have their principal place of business, and were served in Albany County; § 1-5-108 requires filing where a defendant resides or is summoned (i.e., actually served)	Reversed. § 1-5-108 requires filing in the county where a defendant resides or is summoned; none were summoned in Sheridan County, so venue was improper and dismissal without prejudice is required.

Bourke v. Grey Wolf Drilling Co., 305 P.3d 1164 (establishes that the permissive phrase "may be brought" in venue statutes is narrowly limited to the specific options listed)
Saunders v. Saunders, 445 P.3d 991 (standard of review for venue rulings)
State Farm Mut. Auto. Ins. Co. v. Kunz, 186 P.3d 378 (definition and purpose of venue)
Anderson v. Bd. of Cnty. Comm’rs of Teton Cnty., 217 P.3d 401 (statutory "shall" makes venue mandatory when applicable)
Corkill v. Knowles, 955 P.2d 438 (statutory interpretation: avoid absurd results and presume legislature's reasoned intent)
Cattle Brokers, Inc. v. Billings, 346 N.W.2d 264 (Neb.) (interpreting "may be summoned" to require actual summoning for venue)
Hixon v. Chamberlin, 243 P. 183 (Okla.) (construing "may be summoned" conjunctively with "resides" to require voluntary presence where service may occur)