Can You Sue for a Botched Investigation in Wyoming? A Look at Civil Rights and Negligent Investigation Claims

When law enforcement officers make mistakes during a criminal investigation, the consequences can be devastating—especially if those errors lead to false charges or damage someone’s reputation, property, or livelihood. A 2024 Wyoming Supreme Court case, Palm-Egle v. Briggs, sheds important light on whether suspects can bring civil rights and negligence claims when officers don’t do their job properly. 

The Background: Hemp or Marijuana? 

In Palm-Egle v. Briggs, a Wyoming farmer, Deborah Palm-Egle, was criminally charged after a law enforcement officer suspected her of growing marijuana on her property. However, she had evidence that the crop was actually legal hemp. Despite this, Officer Briggs allegedly failed to thoroughly investigate or disclose lab reports showing 0.0% THC—evidence that could have stopped charges from being filed in the first place. 

Ultimately, all criminal charges against Palm-Egle were dismissed. She then sued the officer and the Wyoming Division of Criminal Investigation for civil rights violations under 42 U.S.C. § 1983 and for negligent investigation under Wyoming state law. 

What Did the Wyoming Supreme Court Say? 

The federal court sent key legal questions to the Wyoming Supreme Court: 

1. Do law enforcement officers owe a duty of care to suspects to investigate non-negligently? 

2. Can officers claim qualified immunity from such claims under Wyoming law? 

Yes to the Duty of Care 

The Court ruled that Wyoming law does impose a common law duty of care on officers to act as “reasonable peace officers of ordinary prudence under like circumstances.” This means that suspects can sue if they can prove that the officer conducted the investigation negligently and caused harm. 

This is a significant decision because not all states recognize this kind of claim—many bar lawsuits for negligent investigation altogether. 

Yes to Qualified Immunity 

However, the Court also said that officers are entitled to assert qualified immunity under state law. This means officers may avoid liability unless the plaintiff can show that their rights were violated in a clearly established way. 

Why This Matters 

This case confirms two big things for Wyoming: 

• You can sue if a law enforcement officer conducts a sloppy or incomplete investigation that harms you. 

• But winning is hard—you must prove that the officer acted unreasonably and that you were harmed as a direct result. 

Real-World Consequences 

In Palm-Egle’s case, she argued that: 

• The officer failed to mention exculpatory lab results during the investigation. 

• He relied on flawed evidence to pursue criminal charges. 

• These failures caused her to suffer reputational, emotional, and economic harm. 

Whether or not she ultimately wins the case is still up to the courts—but thanks to this ruling, her lawsuit can move forward under negligence theories. 

Takeaways for Wyoming Residents 

• If you’re the target of a criminal investigation, law enforcement has a legal duty to act with care. 

• You may have legal recourse if you’re wrongly charged due to a negligent or biased investigation. 

• Civil rights protections under § 1983 remain available if your constitutional rights are violated. 

• But officers can and often do claim qualified immunity, so you’ll need strong facts and legal support.