William L. Lopez v. Samantha Ritter

Wyoming Supreme Court·Decided August 10, 2026·No. S-25-0295·Published

Opinion

IN THE SUPREME COURT, STATE OF WYOMING

2026 WY 89

APRIL TERM, A.D. 2026

August 10, 2026

WILLIAM L. LOPEZ,

Appellant (Defendant),

v. S-25-0295

SAMANTHA RITTER,

Appellee (Plaintiff).

Appeal from the District Court of Campbell County The Honorable James Michael Causey, Judge

Representing Appellant:

Justin C. Mankin and Zachary A. Musgrove, Montgomery | Amatuzio, Denver, Colorado. Argument by Mr. Musgrove.

Representing Appellee:

Jeremy J. Hugus and Benjamin Scherner, Platte River Injury Law, Casper, Wyoming. Argument by Mr. Hugus.

Before BOOMGAARDEN, C.J., and GRAY, FENN, JAROSH, and HILL, JJ.

NOTICE: This opinion is subject to formal revision before publication in Pacific Reporter Third. Readers are requested to notify the Clerk of the Supreme Court, Supreme Court Building, Cheyenne, Wyoming 82002, of any typographical or other formal errors so that correction may be made before final publication in the permanent volume.

GRAY, Justice.

[¶1] Several years after a January 2015 car accident, Samantha Ritter sued William Lopez. Ms. Ritter served Mr. Lopez via the nonresident motorist statute, Wyo. Stat. Ann. § 1-6-301, and the district court granted default judgment in favor of Ms. Ritter. Mr. Lopez appeals, arguing Ms. Ritter failed to perfect service because she did not exercise due diligence prior to attempting service under the statute. Mr. Lopez also contends service violated due process, contests the district court’s reinstatement of the matter after an initial dismissal without prejudice for failure to prosecute, and claims the district court abused its discretion when it denied his Wyoming Rule of Civil Procedure 60 (Rule 60) motion seeking relief from the default judgment. We affirm.

ISSUES

[¶2] We rephrase the issues:

1. Did Mr. Lopez waive his arguments that service under Wyo. Stat. Ann. § 1-6-301 was not perfected and that such service violated due process?

2. Did Ms. Ritter exercise sufficient due diligence to invoke substituted service under Wyo. Stat. Ann. § 1-6-301?

3. Did the district court lack personal jurisdiction over Mr.

Lopez when it granted default judgment to Ms. Ritter?

4. Does this Court have jurisdiction to consider whether the district court erred in granting Ms. Ritter’s Rule 60 motion and reinstating the case after it was dismissed without prejudice?

5. Did the district court abuse its discretion when it denied Mr.

Lopez’s Rule 60 motion?

FACTS

A. Procedural History

[¶3] Four years after a January 2015 car accident in Gillette, Wyoming, Ms. Ritter sued Mr. Lopez. Ms. Ritter asked the Campbell County Sheriff’s Office to serve Mr. Lopez at the address identified in the accident report. Deputies from the Campbell County Sheriff’s Office unsuccessfully attempted service at that address and then advised Ms. Ritter that the property was vacant. Ms. Ritter attempted substituted service using the nonresident

motorist statute, Wyo. Stat. Ann. § 1-6-301(a), which requires filing the complaint and summons with the Secretary of State and mailing copies to the defendant’s last known address.

[¶4] On May 1, 2019, copies of the summons and complaint were mailed to Mr. Lopez at the vacant address. Ms. Ritter filed a copy of the Secretary of State’s notice of service, along with an affidavit of compliance with the statute from Ms. Ritter’s attorney (the May 23, 2019 Affidavit) with the district court. 1 Mr. Lopez did not file an answer, and Ms. Ritter requested entry of default. After receiving Ms. Ritter’s proposed entry of default, the district court sent her counsel a letter pointing out that he had failed to file a motion formally seeking entry of default. It also raised a “more substantive concern” that substitute service under the nonresident motorist statute requires “further explanation of the attempts made by Plaintiff to locate Defendant and to achieve personal service [and concluded] this court believes a diligent search for a defendant must be evidenced before the court should permit service under § 1-6-301.” Counsel for Ms. Ritter filed a motion seeking entry of default and a declaration detailing his efforts to locate Mr. Lopez (the March 30, 2020 Declaration). The motion stated:

2. On February 8, 2019, the Campbell County Sheriff’s Office unsuccessfully attempted to effect personal service on [Mr. Lopez] at the address listed on the accident report, . . . but returned the Summons and Complaint and Jury Demand unserved after being advised that the residence is vacant. . . .

3. Pursuant to Wyo. Stat. § 1-6-301, [Ms. Ritter’s] counsel served the Wyoming Secretary of State with the Summons and the Complaint and Jury Demand on April 30, 2019. . . .

4. On May 1, 2019, the Wyoming Secretary of State then mailed a copy of the same to [Mr. Lopez’s] last known address by Certified Mail, thereby effecting service on Defendant pursuant to Wyo. Stat. § 1-6-301. . . .

1 In pertinent part, the May 23, 2019 Affidavit avers:

4. The Campbell County Sheriff’s Department attempted to serve the Summons and the Complaint and Jury Demand upon Defendant William Lopez on several occasions and was unsuccessful. 5. Pursuant to Wyo. Stat. § 1-6-301, [Ms. Ritter’s] counsel served the Wyoming Secretary of State with the Summons and the Complaint and Jury Demand on April 30, 2019. . . . 6. On May 1, 2019, the Wyoming Secretary of State then mailed a copy of the same to Defendant’s last known address by Certified Mail.

5. [Ms. Ritter’s] counsel made subsequent attempts to contact [Mr. Lopez] by phone and locate [Mr. Lopez’s] whereabouts but was unable to speak with or locate [Mr. Lopez].

The March 30, 2020 Declaration identified identical steps. The clerk entered default on April 17, 2020. The matter sat idle until, on December 13, 2021, the district court issued a notice warning that dismissal for failure to prosecute was imminent. On September 8, 2023, the district court dismissed the action without prejudice.

[¶5] On September 15, 2023, Ms. Ritter filed a Rule 60 motion seeking relief from the dismissal. The district court granted the motion and reinstated the case on November 27, 2023. The district court then held a hearing on Ms. Ritter’s motion for entry of default judgment and entered default judgment in favor of Ms. Ritter and awarding damages of $154,661.25.

[¶6] Mr. Lopez filed a Rule 60 motion seeking relief from the default judgment. After a hearing, the district court denied the motion. Mr. Lopez timely appealed.

B. W.R.A.P. 3.03 Statement of the Evidence

[¶7] The Rule 60 hearings before the district court were not recorded. Pursuant to W.R.A.P. 3.03, Mr. Lopez submitted a proposed statement of evidence. Ms. Ritter objected to Mr. Lopez’s statement and submitted her own. The district court accepted Ms. Ritter’s statement of the evidence and proceedings as “consistent with the Court’s understanding and recollection of both [Rule 60] hearings” and entered an order settling the evidence. The following facts are taken from the order which adopted Ms. Ritter’s statement of the evidence:

• At the February 21, 2024 hearing on Ms. Ritter’s motion for entry of default judgment, the following evidence was adduced:

o The [May 23, 2019 Affidavit] submitted by Ms. Ritter’s attorney did not comprehensively list the efforts made to locate Mr. Lopez for personal service.

o The Campbell County Sheriff attempted service at Mr. Lopez’s last known address multiple times between January 29, 2019, and February 8, 2019.

o The Sheriff ultimately learned the location was believed to be vacant and the person providing that information to the Sheriff had no additional information as to Mr. Lopez’s whereabouts.

o No forwarding address for Mr. Lopez was available from the United States Postal Service.

o Prior to perfecting service through the Wyoming Secretary of State’s office, Ms. Ritter attempted to locate an updated physical address through Mr. Lopez’s insurer, but the insurer either did not have, or was unwilling to provide, that information.

Free access — add to your briefcase to read the full text and ask questions with AI

William L. Lopez v. Samantha Ritter, (Wyo. 2026).

William L. Lopez v. Samantha Ritter (William L. Lopez v. Samantha Ritter) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Midway Oil Corp. v. Guess
714 P.2d 339 (Wyoming Supreme Court, 1986)
Claassen v. Nord
756 P.2d 189 (Wyoming Supreme Court, 1988)
McGarvin-Moberly Construction Co. v. Welden
897 P.2d 1310 (Wyoming Supreme Court, 1995)
M & a Construction Corp. v. Akzo Nobel Coatings, Inc.
936 P.2d 451 (Wyoming Supreme Court, 1997)
Colley v. Dyer
821 P.2d 565 (Wyoming Supreme Court, 1991)
Pease Brothers, Inc. v. American Pipe & Supply Co.
522 P.2d 996 (Wyoming Supreme Court, 1974)
Gookin v. State Farm Fire & Casualty Insurance Co.
826 P.2d 229 (Wyoming Supreme Court, 1992)
Fluor Daniel (NPOSR), Inc. v. Seward
956 P.2d 1131 (Wyoming Supreme Court, 1998)
Carlson v. Bos
740 P.2d 1269 (Utah Supreme Court, 1987)
Painovich v. Painovich
2009 WY 116 (Wyoming Supreme Court, 2009)
Vanasse v. Ramsay
847 P.2d 993 (Wyoming Supreme Court, 1993)
Dirks v. Jimenez
2015 WY 36 (Wyoming Supreme Court, 2015)
Rosty v. Skaj
2012 WY 28 (Wyoming Supreme Court, 2012)
Evans v. Moyer
2012 WY 111 (Wyoming Supreme Court, 2012)
RDG Oil & Gas, LLC v. Jayne Morton Living Trust
2014 WY 102 (Wyoming Supreme Court, 2014)
Davis v. State
415 P.3d 666 (Wyoming Supreme Court, 2018)