Kelley v. Watson

Summary

The Supreme Court of Wyoming summarily affirmed a district court judgment awarding two tow trucks to Malcolm G. Watson in a dispute involving vehicle ownership, loans, and alleged trespass and conversion. The court held that the pro se appellants' brief lacked framed issues, cogent argument, pertinent authority, and record support, and that the absence of a hearing transcript required presuming the regularity of the trial court's judgment.

Holdings

1. The Wyoming Supreme Court may summarily affirm an appeal or issues that are not supported by cogent argument or pertinent authority, and pro se litigants are not excused from complying with that requirement or with the Wyoming Rules of Appellate Procedure.
2. In the absence of a hearing transcript or an approved statement of the evidence under W.R.A.P. 3.03, the regularity of the trial court's judgment and the competency of the evidence supporting it must be presumed.

Questions Presented

1. Whether the appeal should be summarily affirmed because the Kelleys' pro se brief failed to present framed issues, cogent argument, pertinent authority, record citations, and required procedural information.
2. Whether the absence of a hearing transcript or approved statement of the evidence required the appellate court to presume the regularity of the district court's judgment and the competency of the evidence supporting it.

Disposition

affirmed