Hall v. Hall

In Hall v. Hall, 708 P.2d 416, 421 (Wyo. 1985), the trial court announced in midtrial that it would not hear additional testimony from the defendant and it would limit the plaintiff to one rebuttal witness. 708 P.2d at 419. The Court determined in Hall that the trial court erred by limiting the parties' right to call witnesses and present evidence. 708 P.2d at 421. The Court then examined that error in light of W.R.C.P. 61, which provides: "No error in either the admission or the exclusion of evidence and no error or defect in any ruling or order or in anything done or omitted by the court or by any of the parties is ground for granting a new trial or for setting aside a verdict or for vacating, modifying or otherwise disturbing a judgment or order, unless refusal to take such action appears to the court inconsistent with substantial justice. The court at every stage of the proceeding must disregard any error or defect in the proceeding which does not affect the substantial rights of the parties." With that rule in mind, the Court held that the trial court's error was harmless because the appellant failed to show that, given more time, she could have presented something not already presented. 708 P.2d at 422.