Bird v. Lampert

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's pro se complaint filed under the Declaratory Judgment Act alleging that the Wyoming Department of Corrections (WDOC) violated certain policies and procedures during disciplinary proceedings brought against him, holding that Appellant was not entitled to relief. Specifically, the Court held (1) Appellant did not have standing to seek a general declaration that the WDOC must abide by its own rules and regulations, and the district court properly considered standing in dismissing Appellant's complaint even though the WDOC did not raise the standing issue in its motion to dismiss; and (2) collateral estoppel and res judicata barred Appellant's claims that procedural violations occurred during his disciplinary proceedings. View "Bird v. Lampert" on Justia Law