Wyoming

What is the law?

Binding, on-point law (about)

None

Advisory sources (about)

None

Public records law (about)

Wyoming has recognized a limited common law right of access to public records at least since 1931. See State ex rel. Romsa v. Grace, 43 Wyo. 454, 5 P.2d 301, 303 (1931). The current Wyoming Sunshine Law may be found at Wyo. Stat. Ann. § 16-4-201.

Does the public records law restrict the use of disclosed records?

Wyoming does not require requestors to demonstrate a need for records in order for them to be disclosed. Laramie River Conservation Council v. Dinger, 577 P.2d 731, 773 (Wyo. 1977).

Specifics and examples (about)

Status	Applies to...	Based on?
Copyrightable by statute	Intellectual property of the Wyoming Business Council	Wyo. Stat. Ann. § 9-12-104
Copyrightable by statute	Intellectual property of the Wyoming Lottery Corporation	Wyo. Stat. Ann. § 9-17-107
Copyright asserted by the state	Wyoming Statutes [1]	Wyoming Statutes

Additional things to consider (about)

Several places in the Wyoming code refer to government records, either in the aggregate or in regard to specific records, as "property of the state": Wyo. Stat. Ann. § 9-2-410 ("All public records are the property of the state"); Wyo. Stat. Ann. § 9-1-902 ("records [of the state engineer's] work, observations and calculations, all of which shall be the property of the state"); Wyo. Stat. Ann. § 9-2-803 ("records of all work done by [state geologist] or under his supervision, all of which shall be the property of the state"). Wyoming also penalizes the unauthorized removal of records. Wyo. Stat. Ann. § 9-2-419.

Where else to go

Reporters Committee for Freedom of the Press, Open Government Guide: Access to Public Records and Meetings in Wyoming, available at http://www.rcfp.org/rcfp/orders/docs/ogg/WY.pdf.
Wyoming State Archives, available at http://wyoarchives.state.wy.us/Index.aspx.

Bibliography

Cases

State ex rel. Romsa v. Grace, 43 Wyo. 454, 5 P.2d 301, 303 (1931), available at https://casetext.com/case/state-ex-rel-romsa-v-county-clerk?page=303.
Laramie River Conservation Council v. Dinger, 577 P.2d 731, 773 (Wyo. 1977), available at https://scholar.google.com/scholar_case?case=13057873378273009345.

Statutes

Wyoming Statutes, available at http://legisweb.state.wy.us/titles/statutes.htm.
Wyo. Stat. Ann. § 16-4-201.
Wyo. Stat. Ann. § 9-12-104.
Wyo. Stat. Ann. § 9-17-107.
Wyo. Stat. Ann. § 9-2-410.
Wyo. Stat. Ann. § 9-1-902.
Wyo. Stat. Ann. § 9-2-803.
Wyo. Stat. Ann. § 9-2-419.

Footnotes

[1] This assertion of copyright is inconsistent with established federal law on the copyrightability of primary sources of law including state statutes. Judicial opinions cannot be copyrighted. The Supreme Court in Banks v. Manchester, 128 U.S. 244, 9 S. Ct. 36, 32 L. Ed. 425 (1888) invalidated an asserted copyright by a private publisher, an Ohio citizen, for copyright in the state court reports, holding that any content written by a judge cannot be copyrighted because "[t]he whole work done by the judges constitutes the authentic exposition and interpretation of the law, which, binding every citizen, is free for publication to all, whether it is a declaration of unwritten law, or an interpretation of a constitution or a statute." See also Nash v. Lathrop, 142 Mass. 29, 35, 6 N.E. 559, 560 (1886) and Wheaton v. Peters, 33 U.S. 591, 668, 8 L. Ed. 1055 (1834). Only materials ancillary to the court opinion such as the "title-page, table of cases, head notes, statements of facts, arguments of counsel, and index" may be copyrighted. Callaghan v. Myers, 128 U.S. 617, 649, 9 S. Ct. 177, 185, 32 L. Ed. 547 (1888).