On June 18, 2026, the Wyoming Supreme Court issued a decision that will reshape how injured workers and their attorneys evaluate third-party claims against coworkers. In Courtney v. Meyer, No. S-25-0260, the court upheld summary judgment against an injured garbage truck worker, clarifying that ordinary negligence by a coworker is not enough to escape workers’ compensation’s exclusive remedy bar. The ruling draws a sharp line: to pursue a personal injury lawsuit against a fellow employee in Wyoming, an injured worker must prove co-employee liability willful wanton conduct workers compensation — a demanding standard that requires showing the coworker knew their actions created a high probability of serious harm and acted in conscious disregard of that risk.
What Happened in Courtney v. Meyer (2026)
The facts of the case involve a worker injured during garbage truck operations when a coworker’s actions resulted in a hand-pinch injury. The injured worker, Courtney, argued that his coworker Meyer’s conduct went beyond ordinary carelessness and should expose Meyer to personal tort liability outside of the workers’ compensation system. The Wyoming Supreme Court disagreed and upheld the lower court’s grant of summary judgment in Meyer’s favor.
The court’s reasoning was methodical. It confirmed that Wyoming’s workers’ compensation system operates as the exclusive remedy for most on-the-job injuries — meaning an injured employee generally cannot sue their employer or coworkers in civil court, no matter how careless the coworker’s behavior was. The critical question in Courtney v. Meyer was whether Meyer’s conduct crossed the threshold from ordinary negligence into co-employee liability willful wanton conduct workers compensation territory. The court concluded it did not, specifically because the evidence failed to show that Meyer had actual knowledge of a specific, high-probability risk of harm at the moment of the incident.
Wyoming’s Workers’ Compensation Exclusive Remedy Rule Explained
Wyoming’s workers’ compensation framework is built on a trade-off familiar across the United States: employees give up the right to sue their employers in tort in exchange for guaranteed, no-fault benefits when they are injured on the job. This “exclusive remedy” doctrine is codified in Wyoming Statutes Title 27, which governs worker compensation rights and employer immunity. Notably, Wyoming’s workers’ compensation base rates decreased 15% in 2026, marking the third consecutive year of reductions and a cumulative drop of 33% over three years — a sign that the system is functioning more efficiently even as legal standards grow more demanding for injured workers.
However, the exclusive remedy rule has important exceptions. Wyoming law recognizes that workers may bring a tort action against a third party whose negligence contributed to the injury. When that third party is a coworker rather than a stranger, the analysis gets complicated. Courts have long struggled with where to draw the line between a compensable workers’ comp claim and an actionable civil suit against a fellow employee. The Courtney v. Meyer decision in 2026 offers the most current and authoritative guidance on that line in Wyoming.
The Willful and Wanton Standard: What It Actually Means
Under Wyoming law, a coworker can face personal civil liability only if their conduct rises to the level of willful and wanton misconduct. This is a significantly higher bar than ordinary negligence. Negligence asks whether a reasonable person would have acted differently. Willful and wanton conduct asks something far more searching: did the coworker actually know — subjectively, not just constructively — that their actions were creating a high probability of serious harm, and did they proceed anyway in conscious disregard of that risk?
The distinction matters enormously in practice. A coworker who rushes through a safety checklist and causes an accident has likely been negligent. A coworker who is explicitly warned that a machine is malfunctioning, acknowledges the warning, and forces a colleague to operate it anyway may have crossed into willful and wanton territory. The gap between those two scenarios is where most co-employee liability cases are won or lost.
In Courtney v. Meyer, the court focused heavily on the knowledge element. Even if Meyer’s actions were careless, Courtney could not produce evidence showing Meyer was subjectively aware of a specific, imminent, high-probability risk at the moment the injury occurred. Without that subjective awareness, the willful and wanton standard simply was not met, and the exclusive remedy bar remained firmly in place.
Workers’ Compensation vs. Third-Party Claims: A Statistical Snapshot
Understanding the financial stakes helps explain why injured workers and their attorneys pay close attention to cases like Courtney v. Meyer. In 2026, the national average workers’ compensation settlement is approximately $29,750. That figure, however, masks an enormous range: minor fractures may settle for as little as $3,000, while catastrophic spinal cord or traumatic brain injuries can exceed $500,000. When a third-party civil claim is available — whether against a coworker, a contractor, or an equipment manufacturer — the potential recovery can dwarf what workers’ compensation alone would provide.
Wyoming’s workplace injury picture adds further urgency to these decisions. Although Wyoming occupational fatalities decreased from 45 in 2023 to 37 in 2024, the state still ranks among the top five in the nation for workplace death rates, according to 2026 data from Sokolov Law. Industries like oil and gas extraction, construction, and agriculture continue to drive that elevated rate. For families who have lost a worker in one of these industries, the difference between a workers’ comp death benefit and a successful wrongful death lawsuit against a negligent third party can be financially life-altering.
Practical Implications for Injured Workers in Wyoming
The Courtney v. Meyer ruling does not eliminate the possibility of suing a coworker — it simply clarifies how high the bar is. For injured workers and their legal counsel, the decision points toward several practical strategies.
Negligence vs. Willful and Wanton Conduct
The first task after any serious workplace injury is to assess whether the coworker’s behavior was merely careless or something more. Evidence of prior warnings, repeated safety violations, and explicit acknowledgment of known risks is far more valuable than evidence of general sloppiness. Begin gathering that evidence as early as possible, before witnesses’ memories fade and records are purged.
The Knowledge Requirement After Courtney v. Meyer
The court’s emphasis on subjective knowledge means that circumstantial evidence of awareness is critical. Text messages, safety meeting logs, OSHA inspection reports, prior incident reports, and witness statements about what the coworker was told before the incident can all be relevant. The goal is to build a record showing the coworker did not merely overlook a risk — they knew about it and chose to ignore it.
Document Everything That Points to Subjective Awareness
In the immediate aftermath of a workplace injury, documentation is everything. Photograph the scene, preserve equipment, collect contact information for witnesses, and request copies of any safety logs, training records, or communications related to the hazard that caused the injury. This evidence becomes exponentially harder to obtain as time passes.
Understand the Limits of Safety Violations Alone
A coworker who violated a safety rule is not automatically liable under the willful and wanton standard. The violation must be accompanied by evidence that the coworker knew the rule existed, understood the specific risk the rule was designed to prevent, and consciously chose to disregard it in a way that created a high probability of harm. Safety violations are a starting point, not a finishing line.
Fatal Workplace Accidents and Third-Party Claims
When a workplace accident results in death, the stakes of getting the legal strategy right are at their highest. Surviving family members may have claims not only through Wyoming’s workers’ compensation death benefits but also through wrongful death actions against third parties — including, potentially, coworkers whose conduct meets the willful and wanton threshold. Given Wyoming’s persistently high fatality rate even as raw numbers improve, these cases will continue to arise with troubling regularity.
How This Decision Fits the Broader National Landscape
Wyoming is not alone in wrestling with where to draw the line between workers’ compensation exclusivity and co-employee tort liability. Courts across the country apply varying standards, and high-stakes verdicts in third-party cases remind us how much money can turn on the outcome. In February 2026, a New Jersey jury handed down a $19 million verdict in a case stemming from a Christmas Day 2018 Uber crash — a case that took seven years to reach resolution. While that case involved a rideshare driver rather than a coworker, it illustrates a broader point: when injured parties can successfully step outside the workers’ compensation framework and into civil court, the financial consequences can be transformative.
The tension between workers’ compensation exclusivity and civil liability is playing out in legislatures and courtrooms nationwide in 2026. Some states have moved to broaden co-employee liability exceptions; others have tightened them. Wyoming’s Courtney v. Meyer decision signals that the state’s Supreme Court is firmly committed to the exclusivity principle, reserving civil liability for only the most egregious coworker conduct. For workers in high-risk industries who are injured in Wyoming, that means understanding the willful and wanton standard is not optional — it is essential.
Frequently Asked Questions
Can I sue a coworker who injured me in Wyoming?
Yes, but only under narrow circumstances. Wyoming’s workers’ compensation system is the exclusive remedy for most on-the-job injuries, which means you generally cannot sue your employer or a coworker in civil court. The exception arises when a coworker’s conduct rises to the level of willful and wanton misconduct — meaning the coworker subjectively knew their actions created a high probability of serious harm and proceeded in conscious disregard of that risk. Ordinary negligence, even serious negligence, is not enough under the standard reinforced by Courtney v. Meyer in 2026.
What is the difference between willful and wanton conduct and ordinary negligence in a Wyoming workers’ comp context?
Ordinary negligence means a person failed to act as a reasonable person would under the circumstances — carelessness, inattention, or a lapse in judgment. Willful and wanton conduct requires something more: actual, subjective knowledge of a specific risk of serious harm, combined with a conscious decision to proceed despite that knowledge. In the workers’ compensation context, this distinction is the difference between being limited to comp benefits and having the right to pursue a personal injury lawsuit against a fellow employee.
What evidence do I need to prove co-employee liability willful wanton conduct workers compensation claims in Wyoming?
After Courtney v. Meyer, the most critical evidence is anything that shows the coworker’s subjective awareness of the specific risk. This includes prior safety warnings directed at the coworker, written or electronic communications acknowledging the hazard, OSHA citations or inspection records, incident reports involving the same equipment or conditions, and witness testimony about what the coworker was told before the accident. General evidence of a dangerous workplace is not sufficient on its own — you need evidence tied to what that specific coworker knew at the time of the injury.
Does the Courtney v. Meyer 2026 decision affect my ability to collect workers’ compensation benefits?
No. The decision addresses only the narrow question of when an injured worker can pursue a civil lawsuit against a coworker in addition to — or instead of — workers’ compensation benefits. Your right to collect workers’ compensation benefits for a covered on-the-job injury is not affected by this ruling. If anything, the decision reinforces the importance of workers’ compensation as the primary safety net for injured workers whose claims do not meet the willful and wanton threshold.
Are there workplace injury situations where a coworker could still face personal liability after this Wyoming ruling?
Yes. The Courtney v. Meyer decision did not eliminate co-employee liability — it clarified the evidentiary standard required to establish it. Cases involving explicit prior warnings that were ignored, deliberate disabling of safety equipment, or conduct so reckless that it demonstrates conscious indifference to a known, high-probability risk of harm could still satisfy the willful and wanton standard. Each case turns on its specific facts, and the outcome depends heavily on the quality and specificity of the evidence showing what the coworker knew and when they knew it.
David Prescott is a Workers Rights and Injury Specialist with extensive knowledge of personal injury law and settlement values across the United States. With years of experience analyzing workplace injury claims only cases, David helps injury victims understand their legal rights and the potential value of their claims. David is not an attorney and the information provided is for educational purposes only.