Boyd filed an amended complaint, alleging that Nation was the mayor of Evansville and, as such, was a co-employee of Boyd. Boyd also alleged that he had complied with the Wyoming Governmental Claims Act and properly made demand on the Town of Evansville for payment of his claims. Nation later filed a motion for summary judgment. After briefing by the parties and a hearing, the district court granted Nation's motion for summary judgment. It is fundamental, if not axiomatic, that, before a court can render any decision or order having any effect in any case or matter, it must have subject matter jurisdiction.
Jurisdiction is essential to the exercise of judicial power.
Unless the court has jurisdiction, it lacks any authority to proceed, and any decision, judgment, or other order is, as a matter of law, utterly void and of no effect for any purpose. Subject matter jurisdiction, like jurisdiction over the person, is not a subject of judicial discretion. There is a difference, however, because the lack of jurisdiction over the person can be waived, but lack of subject matter jurisdiction cannot be. Subject matter jurisdiction either exists or it does not and, before proceeding to a disposition on the merits, a court should be satisfied that it does have the requisite jurisdiction. It is apparent from the record that the district court in this case was not presented with information sufficient to establish that it had the requisite jurisdiction to hear this case.