Abeyta v. State
In Abeyta v. State, 2003 WY 136, 78 P.3d 664 (Wyo. 2003), the defendant claimed the State failed to prove his prior family violence convictions.
The Court did not address the merits of the claim, but did say that prior convictions could be established through authenticated copies of judgments and sentences. Abeyta, however, did not address the question of subject matter jurisdiction.