Courts interpret statutes based on the plain meaning of the law. However, when the plain meaning of the law is ambiguous, a court tries to determine what the legislature intended when writing the statute. In this case, researching the legislative history of a law might be necessary. This requires gathering official background documents leading up to a law's enactment. For a comprehensive discussion of the legislative process across jurisdictions, see Singer's Statutes and Statutory Construction, 8th ed., KF 425 .S56 2018 in our treatise section.

Developing a complete history of Wyoming legislation can be difficult, but electronic access is improving. Unpublished materials that are available can be accessed from the Wyoming State Library and the Legislative Service Office (LSO), both in Cheyenne.

Basic Process of Legislation

Sponsor requests draft of bill from the Legislative Service Office and approves draft	LSO has bill drafting files from 1977 on, available to public only on approval from the Director.
Unique bill number is assigned	Bills since 2000 are available at the LSO, and those dating back to 1879 are available at Wyoming Legislation.
Bill is prefiled	LSO has copies of all prefiled bills since 1971
Introduction of bill by sponsor
Bill is referred to committee
Committee reports to full legislative body	There are no transcripts of floor debates; however, audio tapes are available at the State Library since about 1995 and on the LSO web site since 2006.
Bill is referred to conference committee	Conference committee recommendations are published in the Wyoming Digest of Senate and House Journals.  The Digest records all action taken on a bill and is available on the web back to 2001 and at Wyoming Legislation back to 1869.
Bill is passed by individual houses of the legislature	Amended copies of bills for the current legislative session are available at the LSO.
Governor signs or vetoes	Governor's messages approving or vetoing bills are kept with the bill and may be retrieved from the Secretary of State's Office.  LSO has gubernatorial veto messages from 1975 to present.
Bill is assigned a chapter number and enacted into law.	Enrolled acts are published in the Wyoming Session Laws and available from the LSO web site.  The original bill and all amendments are retained in a bill jacket by the Secretary of State for ten years, then sent to the Archives and Records Management Section of the Department of Commerce. The Law Library has bound original and amended bills for select years.
Session Laws are codified into Wyoming Statutes Annotated	The Wyoming Statutes Annotated, published by Lexis, are current laws of the state arranged by title (topical) and annotated with case law.  West publishes a similar set, West's Wyoming Statutes Annotated.

One Possible Legislative History Search in the University of Wyoming Library:

1. Look up your statute in the Wyoming Statutes Annotated located in the Reference area (M-C-1) or on the LSO web site. Refer to the brief legislative history at the end of the statute for cites to Laws (Wyoming Session Laws), journal articles, and case law.  Note the date, chapter, and section numbers for each reference to Laws, for example:  (Laws 1974, ch. 24, § 2; Laws 1978, ch. 48, § 4).  This information tells you when the law was enacted (the initial reference) and the dates of each amendment along with a citation to retrieve the text of the act.

2.  Look up each of your references in the Wyoming Session Laws (Wyoming KFW 4225 .A3) in the Wyoming section on the second floor.  To find Laws 1974, ch. 24 § 2, retrieve the 1974 Wyoming Session Laws volume and look for Chapter 24, § 2.  The Session Laws contain the final bill passed by both Houses and signed by the governor with the textual changes identified.  From here, take note of the original House bill or Senate file number.  That will assist you to further your research in other resources. The chaptered bill may also contain uncodified text that deals with administrative aspects of the newly enacted law, usually as a brief introduction. Session laws are also available in Hein Online’s State Session Laws database and recent years are on the LSO website.

3. Find the original bill as introduced in the bound volumes of Wyoming House Bills and Senate Files (KFW 4207 .L45) in the Wyoming section of the law library or on the LSO or Wyoming Legislation websites. Comparing the original version of the bills with the amended versions can help you determine the intent of the legislature. For current legislation monitor the website.

4. Use the Wyoming Digest of Senate and House Journals (KFW 12 .L45) in the Wyoming treatise section to find conference committee recommendations (recommendations on whether a bill should be passed based on discussion of both houses together), citations, bill sponsor's names, names of committees that considered the bill, dates of action taken, text of all adopted amendments to the bill and all roll call votes.  This information is also available under Bill Information at the LSO web site and back to 2001 and the Wyoming legislation web site back to 1869.

5. You may want to look at Attorney General Opinions (KFW 4640 .A5587) in the Wyoming treatise section. Sometimes the A.G. reviews legislative history when interpreting a statute. We have the most recent years on reserve and older years in the Wyoming collection. These are also available at the Attorney General's web site.

6. We have a complete collection of the Wyoming Law Review (on Reserve), Wyoming Law Journal, and Land and Water Law Review (on Reserve). Hein Online indexes articles that appear in these publications. Frequently a contributor will write an article discussing a Wyoming statute at length, including some elements of legislative history.

7. Citate the statute in Shepard's or KeyCite to find case law and law review articles that cite it.

04/2020