White v. HA, Inc

In White v. HA, Inc., 782 P.2d 1125 (Wyo. 1989), the plaintiff was a patron in the defendant's bar. One of the plaintiff's friends and another bar patron got into a fight in the bar. The plaintiff and his friend left the bar after the fight. Shortly afterward, the fight resumed outside the bar premises between the plaintiff's friend and the other party to the bar fight. The plaintiff became involved and ultimately sustained a gunshot wound. The Court affirmed a summary judgment in favor of the bar. We noted that the original altercation in the bar was brief and that the bar patron who shot the plaintiff voluntarily left the bar. The plaintiff and that patron did not talk to each other in the bar or demonstrate any aggressive behavior towards each other in the bar. We held that "without sufficient notice of impending danger, no duty arose" to protect the plaintiff. Id. at 1131.