Devous v. Wyoming State Board of Medical Examiners
In Devous v. Wyoming State Board of Medical Examiners, 845 P.2d 408 (Wyo. 1993), the provision at issue stated that the board could take a number of punitive actions against a licensee, including assessing all or part of the cost of the proceedings. 845 P.2d at 418-19; see Wyo. Stat. Ann. 33-26-405(a)(viii) (2003).
Devous reasoned that because of the general rule that parties to litigation bear their own expenses, and because none of its cases had ever held that "costs" included attorney fees and the expenses of the hearing examiner, those expenses were not recoverable. 845 P.2d at 418-19.