In the Interest of SVG
In In the Interest of SVG, 826 P.2d 237 (Wyo. 1992), the trial court granted the agency's summary judgment motion and terminated mother's rights on the grounds of abandonment.
On appeal, the Wyoming Supreme Court recognized that summary judgment may be appropriate. Id. at 244. Although it found that mother's affidavit raised genuine issues of material fact about whether mother had abandoned the child or been excluded from the child, it recognized that summary judgment may be appropriate in the narrow range of parental rights termination cases in which all the historical facts are uncontroverted. Id.