Bird v. Lampert

Summary

The Wyoming Supreme Court affirmed dismissal of Chester Bird's declaratory judgment complaint against the Wyoming Department of Corrections director. The court held that Bird lacked standing to seek a general declaration requiring the Department to follow its policies and that collateral estoppel and res judicata barred claims concerning alleged procedural violations in his prison disciplinary proceedings.

Holdings

1. The district court properly considered standing because lack of standing may be raised at any time, including sua sponte.
2. Bird lacked standing to seek a general declaration that the Wyoming Department of Corrections must follow its own procedures because the requested declaration presented no justiciable controversy and would constitute an advisory opinion concerning future, speculative matters.
3. Collateral estoppel barred Bird's claims to the extent they raised issues identical to those litigated and resolved on the merits in his prior federal habeas proceeding.
4. Res judicata barred Bird's remaining claims because the state action and prior federal action involved the same parties or their agents, the same subject matter, related issues, and identical capacities, and the claims either had been or should have been litigated in the earlier action.

Questions Presented

1. Whether the district court properly considered and dismissed for lack of standing Bird's request for a general declaration that the Wyoming Department of Corrections must follow its own policies and procedures, even though standing was raised for the first time in the defendant's reply brief.
2. Whether collateral estoppel and res judicata barred Bird's claims alleging procedural violations during his disciplinary proceedings.

Disposition

affirmed