Write On!

• Citation: Vol. 48 No. 3 Pg. 52
• Year: 2025
• Pages: 52

Write On! Vol. 48 No. 3 Pg. 52 Wyoming Bar Journal June, 2025

Michael R. Smith

Id. Citation Form for Wyoming Cases

Michael R. Smith is a Professor of Law at the University of Wyoming College of Law and the Director of the Center for the Study of Written Advocacy.

Most legal writers know that the Id. citation form is used in legal memoranda and court documents when a writer is citing the immediately preceding authority in their document and the immediately preceding citation contains only one authority.^[1] What is not clear, however, is the proper format for Id. citations to Wyoming cases. Over the years, I have seen many different approaches to Id. citing in this context. To make matters worse, legal writers in Wyoming frequently face this dilemma because legal writing in Wyoming, not surprisingly, often requires a writer to Id. cite to Wyoming Supreme Court cases. Thus, in this article, I attempt to clear up this "id-eration" (sorry!) of citation confusion.

When citing to a Wyoming case in long form, a lawyer practicing in Wyoming must follow the citation guidelines set out by the Wyoming Supreme Court in its 2000 Order Adopting a Public Domain or Neutral-Format Citation^[2] as amended by its 2005 Order Amending Citation Format.^[3] Except for cases decided before January 1, 2001 (which should be cited to the Pacific Reporter only), long form cites to Wyoming cases generally contain parallel cites to both the Public Domain version of the case and the Pacific Reporter version of the case.^[4]

Under these guidelines for citing Wyoming cases, a long form cite with a pinpoint cite includes three components: (1) the name of the case (in italics), (2) the Public Domain format, which includes the year the case was decided, the abbreviation "WY", the opinion number assigned to that case the year it was decided, a comma, and a pinpoint cite containing the paragraph symbol (¶) followed by a space and the number of the relevant paragraph, and (3) the Pacific Reporter cite, which includes the reporter number, the reporter abbreviation, the number of the page where the case begins in the reporter, a comma, a pinpoint cite to the relevant page(s), and a parenthetical containing the court abbreviation (Wyo.) and the year the case was decided.^[5] The Wyoming Supreme Court offers this example in its Order Amending Citation Format:^[6]

Doe v. Roe, 2001 WY 12, ¶ 44, 989 P.2d 1312, 1320 (Wyo. 2001).

Unfortunately, the Wyoming...