Wyoming

Butterfield v. Forrester in Wyoming Law

How Butterfield v. Forrester applies in Wyoming: state-specific rules, key cases, and bar exam notes for Torts.

State Approach

Wyoming follows the principle of contributory negligence closely, relying on the historical framework set by Butterfield v. Forrester. The state emphasizes the importance of the plaintiff's behavior in the chain of causation leading to the injury, making even slight negligence a bar to recovery in some circumstances.

State Rule
In Wyoming, a plaintiff's contributory negligence can completely bar recovery of damages if it is found that they acted reasonably but still contributed to their injury in a way similar to the principles outlined in Butterfield v. Forrester.
Significant State Cases

Gillett v. Cheyenne, Laramie & Northern Railway

The court held that the plaintiff's negligence contributed to their injury, reinforcing the contributory negligence standard.

Big Horn Coal Co. v. Roberts

This case clarified that the doctrine of contributory negligence applies in Wyoming, aligning with the holding in Butterfield v. Forrester.

Bridger Valley Electric Ass'n v. Yost

The court found that plaintiff's actions that contributed to their injury barred recovery under state negligence law.

Comparison to Federal Law

Wyoming's approach to contributory negligence diverges from the federal comparative negligence standard, which allows for some degree of recovery even when the plaintiff is partially at fault. While federal standards may allow for apportionment of fault, Wyoming's strict adherence to contributory negligence can result in a total bar to recovery.

Bar Exam Note

Understanding the principles of contributory negligence as established in Butterfield v. Forrester is crucial for success on the Wyoming bar exam, particularly in tort law questions involving negligence.

Practice Pointers
  • Always evaluate the actions of both the plaintiff and defendant in negligence cases.
  • Consider how slight negligence on the part of the plaintiff can affect their ability to recover damages.
  • Familiarize yourself with the key cases reinforcing Wyoming's standards on contributory negligence.

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