Brown v. City of Casper

VOIGT, Justice,

dissenting.

[157] I respectfully dissent. The Wyoming Governmental Claims Act (the WGCA) was adopted in 1979. That was 32 years ago. For at least 28 years, this Court has consistently held that district courts do not obtain jurisdiction over governmental claims absent sufficient allegation in the complaint of compliance with procedural requirements. Seq, e.9., Bd. of Trustees of UW v. Bell, 662 P.2d 410, 415 (Wyo.1983), and Churchill v. Campbell County Mem'l Hosp., 2010 WY 86, ¶ 4, 234 P.3d 365, 366 (Wyo.2010). I believe we were right in those cases, and in the dozens of cases in between.

[T¥58] Because the district courts can only adjudicate claims against governmental entities under the narrow confines of the WGCA, I do not believe that, as the majority states, "subject matter jurisdiction [can bel invoked upon the [mere] filing of a complaint alleging a claim against a governmental entity." See supro 19. Such would not even meet the requirements of W.R.C.P. 8(a), no less the WGCA and article 16, section 7 of the Wyoming Constitution.'5 My reading of the majority opinion leads me to conclude that if, in the future, a plaintiff fails to allege compliance with statute and constitution, and the defending governmental entity follows up that failure with a failure of its own to raise the issue, it is waived and the district court can proceed to adjudicate the claim, whether or not it is one for which the legislature waived immunity in the WGCA, and whether or not any procedural requirements were met.6 Stated differently, if the plaintiff does not need to allege compliance, upon what ground does he or she have to prove compliance in the event that the issue is not raised by the defendant?

[159] Even where the "general power over matters of the kind involved in a particular case [exists] the proceeding must be initiated in some particular manner[.]" McGuire v. McGuire, 608 P.2d 1278, 1290 (Wyo.1980) (court rule vs. statute in establishment of private roads); see also Delgue v. Curutchet, 677 P.2d 208, 216 (Wyo.1984) (filing of a new complaint seeking clarification of a judgment "did not appropriately invoke the jurisdiction of the district court"). The nature of the WGCA, with immunity being the rule and Hability the exception, convinces me that, in Wyo. Stat. Ann. § 1-89-117 (Lex-isNexis 2009), the legislature did not grant the district courts jurisdiction over all cases alleging a claim against a governmental entity, but only over those cases alleging claims made "under {the] act." For that reason, I believe that making one's claim under the act is jurisdictional.7

. W.R.C.P. 8(a):

"(a) Claims for relief -A pleading which sets forth a claim for relief, whether an original claim, counterclaim, cross-claim, or third-party claim, shall contain: (1) a short and plain statement of the grounds upon which the court's jurisdiction depends, unless the court already has jurisdiction and the claim needs no new grounds of jurisdiction to support it; (2) a short and plain statement of the claim showing that the pleader is entitled to relief [.]"

(Emphasis added.)

. See W.R.C.P. 8(b), (c) and (d), and 9(c) for the effect of a failure to plead an affirmative defense or condition precedent. Such averments not denied are deemed admitted.

. In 2010, the legislature amended Wyo. Stat. Ann. § 1-39-113 (LexisNexis 2009) by adding subsection (d), which reads as follows:

(d) In any action under this act, the complaint shall state:
(i) That the claim required under subsection (c) of this section was filed in accordance with this section;
(ii) The date the claim under subsection (c) of this section was filed;
Gif) That the claim was in compliance with the signature and certification requirements of article 16, section 7 of the Wyoming Constitution.

Wyo. Stat. Ann. § 1-39-113 (LexisNexis 2010 Supp.). Under the majority opinion, these be*1151come mere suggestions, as opposed to requirements.