WYOMING COURT RULES

218 (2) Time to Appeal Not Affected by Lack of Notice. — Lack of notice of the entry by the clerk does not affect the time to appeal or relieve, or authorize the court to relieve, a party for failure to appeal within the time allowed, except as permitted by the Wyoming Rules of Appellate Procedure. History: Added February 2, 2017, effective March 1, 2017; amended May 2, 2023, effective July 3, 2023. Source. — This rule is similar to Rule 77 of the Federal Rules of Civil Procedure. Service of orders. — For sanctions pur- poses, no hearing is required in the case of an unexplained failure to comply; the onus was on counsel to provide an explanation for his failure to file required pretrial pleadings and appear for the conference, but he did nothing, such that the trial court was well within its discretion to impose the sanction it did in limiting his pre- sentation of evidence without holding a hearing beforehand; nowhere in the record did he ever say that he was unaware that orders were served on attorneys through the clerk’s boxes. Goforth v. Fifield, 2015 WY 82, 352 P.3d 242, 2015 Wyo. LEXIS 93 (Wyo. 2015). Untimely filing of notice of appeal. — Subdivision (d) bars relief from the untimely filing of a notice of appeal when the sole reason asserted for relief is the failure of a litigant to receive notice of the entry of a judgment. Ahearn v. Anderson-Bishop Pshp., 946 P.2d 417, 1997 Wyo. LEXIS 129 (Wyo. 1997). Where a party does not learn of a judgment until after the time provided in W.R.A.P. 2.01(a)(i) to file notice of an appeal, relief under W.R.C.P. 60(b) is available only where the party has shown due diligence, sufficient reason for the lack thereof, or other special circumstances. Ahearn v. Anderson-Bishop Pshp., 946 P.2d 417, 1997 Wyo. LEXIS 129 (Wyo. 1997).