McCulloh v. Drake
In McCulloh v. Drake, 2001 WY 56, 24 P.3d 1162 (Wyo. 2001), the Supreme Court of Wyoming held that a civil action in tort is fundamentally different from a divorce proceeding and ruled that tort claims could not be joined with dissolution proceedings.
As such, the Wyoming court specifically held that principles of res judicata would not bar the former wife's later tort actions, even though Wyoming's allowance of fault factors in the dissolution proceeding resulted in the same issues which served as the basis for the subsequent tort action having been litigated in the dissolution proceeding.
According to the Wyoming court, even the goal of promoting judicial economy is not significant enough to override the fact that the two proceedings are fundamentally different.