The Wyoming Supreme Court issued a ruling Feb. 5, 2026, clarifying procedural requirements for will contests in the state, answering a certified question from the Fremont County District Court regarding the Estate of Lloyd Haack.
The case involves a dispute between co-personal representatives Howard E. Haack and Bailey N. Baxter against Kristy Martinez over the validity of Lloyd Haack's will. The matter reached the state's highest court through a certified question procedure, allowing lower courts to seek guidance on unsettled legal issues.
The certified questions focused on the proper filing procedure for will contests under Wyoming Statute Section 2-6-301 et seq. Specifically, the district court asked whether an action contesting a will's validity must be filed as a completely new and separate civil action with its own case number and heading, entirely apart from the probate matter.
Justice Hill, writing for the court, answered the first question in the negative, meaning will contest actions do not need to be filed as entirely separate proceedings from the underlying probate matter. Because the court answered the first question negatively, it declined to address the second certified question regarding whether failure to file separately would constitute a jurisdictional defect.
The procedural distinction carries practical implications for attorneys and parties involved in estate disputes. Will contests are complex proceedings that can involve challenges to a deceased person's testamentary capacity, allegations of undue influence, or claims of improper execution. The court's ruling provides clarity on how such challenges should be procedurally handled within Wyoming's court system.
The case originated in the Ninth Judicial District under the Honorable Jason M. Conder. The matter proceeded through Wyoming Rules of Appellate Procedure Rule 11, which allows district courts to certify questions of law to the Supreme Court when immediate appellate review would materially advance the litigation's resolution.
Howard E. Haack and Bailey N. Baxter serve as co-personal representatives of Lloyd Haack's estate, giving them authority to manage estate affairs and defend against challenges to the will's validity. Personal representatives have fiduciary duties to estate beneficiaries and must act in the estate's best interests while following statutory requirements.
Kristy Martinez initiated the will contest petition, though the court's opinion does not detail the specific grounds for her challenge. Will contests typically arise when interested parties believe a will was executed under suspicious circumstances, the testator lacked mental capacity, or someone exercised undue influence over the deceased person.
The appellants were represented by a team of attorneys including Nikki E. Horton of Horton Legal P.C. in Riverton, Wyoming, along with Ann E. Davey and Aaron J. Vincent from Vincent Davey Law Firm. Horton presented oral arguments on behalf of the estate representatives.
Paul K. Knight of Knight Law Offices LLC in Dubois, Wyoming, represented Martinez in the proceedings. Knight argued the case for the petitioner seeking to contest the will's validity.
The Supreme Court's composition included Chief Justice Boomgaarden and Justices Gray, Fenn, Jarosh, and Hill. The court noted that the opinion remains subject to formal revision before publication in Pacific Reporter Third, the official reporter for Wyoming Supreme Court decisions.
Certified question procedures serve an important function in the judicial system by allowing appellate courts to provide guidance on novel legal issues without requiring full appeals. This process can save time and resources while ensuring consistent application of law across different courts and cases.
Wyoming's probate statutes govern how estates are administered and provide procedures for challenging wills. The statutes attempt to balance efficient estate administration with protection for interested parties who may have legitimate concerns about a will's validity.
The court's ruling will likely influence how future will contests are filed and managed in Wyoming courts. Estate planning attorneys and probate practitioners will need to consider these procedural requirements when advising clients about potential will challenges.
The decision also highlights the importance of proper procedural compliance in probate matters. While the court ruled that separate filing is not required, parties must still follow established statutory procedures for initiating will contests within the probate proceeding framework.
Estate disputes often involve family members and can be emotionally charged, as appears to be the case here with family members on different sides of the litigation. The court's procedural guidance helps ensure such disputes are resolved efficiently while protecting all parties' rights.
The ruling provides needed clarity for Wyoming's legal community on will contest procedures, potentially reducing future procedural disputes and allowing courts to focus on the substantive merits of estate challenges rather than filing technicalities.