## Facts

- Theresa White and Crawford White sued two physicians and a hospital for medical malpractice, seeking money damages for alleged personal injuries.
- The complaint alleged specific dollar amounts for general and special damages, including amounts in the ad damnum clause or prayer for relief.
- A Wyoming statute, Wyo. Stat. § 1-1-114 (1977), barred pleadings in personal-injury and wrongful-death actions from stating a dollar amount of damages in the ad damnum clause or prayer for damages.
- The hospital answered and incorporated a motion to dismiss, arguing the complaint violated § 1-1-114 by pleading specific dollar amounts.
- The Whites moved to amend the complaint to remove the dollar figures, asserting time pressure from the impending statute of limitations.
- The district court dismissed the complaint for violating § 1-1-114.
- The Whites appealed, arguing § 1-1-114 was unconstitutional because it regulated court procedure and invaded judicial authority.

## Issues

1. Whether Wyo. Stat. § 1-1-114 (1977), which restricts pleading specific dollar amounts of damages, is unconstitutional under the Wyoming Constitution as a legislative intrusion into the judiciary’s authority over practice and procedure.
2. Whether the district court’s dismissal of the complaint based solely on § 1-1-114 must be reversed if the statute is unconstitutional.

## Decision

- The Wyoming Supreme Court held § 1-1-114 unconstitutional as an invasion of the judicial branch’s constitutional powers.
- The Court reversed the dismissal and remanded for further proceedings.
- The Court declined to decide statutory-interpretation questions about the statute’s scope or what sanction would apply for a violation, because the constitutional ruling controlled.

## Legal Principles

- The Wyoming Supreme Court has constitutional and inherent authority to prescribe rules of practice and procedure for state courts under Article V, § 2 of the Wyoming Constitution.
- The legislature may enact substantive law, but it may not prescribe procedural rules that control the form or content of pleadings in a way that conflicts with judicially promulgated rules.
- A statute that attempts to regulate court procedure in an area committed to the judiciary violates separation of powers and is invalid.
- When a procedural statute is unconstitutional, a dismissal premised on that statute cannot stand.

## Conclusion

The Wyoming Supreme Court invalidated a statute restricting the pleading of specific damage amounts because it regulated civil procedure, a domain constitutionally committed to the judiciary, and reversed the trial court’s dismissal entered solely for noncompliance with that statute.


White v. Fisher, 689 P.2d 102 (Wyo. 1984)