Justia Wyoming Supreme Court Opinion Summaries

A group of residents from the Rafter J Ranch Subdivision in Teton County, Wyoming, appealed the Teton County Board of County Commissioners' approval of a petition by Stage Stop, Inc. to amend the Rafter J Planned Unit Development (PUD) to allow the use of Lot 333 for workforce apartments. The residents, referred to as Objectors, argued that the Board's decision was subject to judicial review, that the Board erred by allowing the PUD Amendment without requiring a vacation of the Rafter J Subdivision Plat, and that the Board's approval of the PUD Amendment was arbitrary, capricious, and not in accordance with the law.The District Court of Teton County affirmed the Board's decision. The Objectors then appealed to the Supreme Court of Wyoming. The Objectors argued that the Board's decision was a legislative act and therefore not subject to judicial review. They also claimed that the Board did not follow the proper procedure for amending the PUD and that the Board did not properly consider the requirement that the PUD Amendment comply with the underlying base zoning to the maximum extent practicable.The Supreme Court of Wyoming affirmed the lower court's decision. The court found that the Board's approval of the PUD Amendment was subject to judicial review to determine whether the Board followed its rules and regulations. The court also found that the Board properly considered Stage Stop's request to amend the PUD and that the Board's decision had no effect on any private contractual rights which the Objectors may have from the Plat restrictions. The court concluded that the Board followed the Land Development Regulations (LDRs) and made reasonable choices in approving the PUD Amendment. View "Brazinski v. Board of County Commissioners" on Justia Law

Wesley de Sousa Soares, a Brazilian national and professional jiu jitsu fighter, was charged with four counts of first-degree sexual assault. The charges stemmed from an encounter with a woman, KB, whom he met through an online dating application. KB alleged that Soares sexually assaulted her multiple times at her residence until she managed to escape. Soares, however, claimed that KB had consented to their sexual encounter. While in custody, Soares made phone calls in Portuguese, which were recorded and later translated. These recordings were admitted as evidence during the trial.The District Court of Albany County convicted Soares on three of the four counts. Soares appealed, arguing that the trial court erred in admitting the audio recordings without an accompanying English transcription. He also claimed that the prosecutor committed misconduct during cross-examination and closing arguments, and that the court committed structural error by providing the jury with equipment to listen to the audio exhibits.The Supreme Court of Wyoming disagreed with Soares' arguments. The court found no reversible error in the trial court's admission of the audio exhibits without an English transcription. It also found no prosecutorial misconduct during cross-examination or closing arguments. Lastly, the court acknowledged that the trial court erred in providing the jury with equipment to listen to the audio exhibits without first screening the recordings, but it ruled that this error was not structural and that Soares had waived this claim by failing to object. Consequently, the court affirmed Soares' conviction. View "Soares v. The State of Wyoming" on Justia Law

In this appeal, John Gustke (Father) contests a decision by the District Court of Natrona County, Wyoming, which partially denied several motions to set aside the forfeiture of a $100,000 surety bond. The bond was linked to a criminal case involving Father's son, Karl Gustke (Criminal Defendant), who violated his bond conditions and absconded from the state. Father was jointly liable for the bond through a promissory note and indemnity agreement with the surety and surety's insurer. The District Court also denied Father's motion to intervene in the case as a matter of right under Rule 24(a)(2) of the Wyoming Rules of Civil Procedure (W.R.C.P.), without giving notice to Father.The Supreme Court of Wyoming found that the District Court had erred by not providing Father with notice and a meaningful opportunity to be heard on his motion to intervene. The court reversed the District Court's order denying Father's motion to intervene and remanded the case for a properly noticed hearing and for any further proceedings consistent with this opinion. The Supreme Court did not reach a decision on the remission of the bond, stating that it would be premature given the District Court's error. View "Gustke v. The State of Wyoming" on Justia Law

The case in question concerns the termination of parental rights and involves Chelsey Marie Smith (the Mother) who appealed the decision of the district court granting the Wyoming Department of Family Services’ (the Department) petition to terminate her parental rights to her children, under Wyo. Stat. Ann. § 14-2-309(a)(iii) and (v) (2023). The children were initially removed from the Mother's care due to neglect, and despite the Department's efforts to rehabilitate the family, the Mother was unable to consistently abide by the objectives set out in the Department’s case plan.The Supreme Court of Wyoming affirmed the district court's decision, concluding that clear and convincing evidence supported that the Department made reasonable but unsuccessful efforts to rehabilitate the Mother and reunify her with the children under Wyo. Stat. Ann. § 14-2-309(a)(iii). The court noted that while the Mother had a fundamental right to raise her children, the children also had a right to stability and permanency in their family relationships. View "In the Matter of the Termination of Parental Rights To: Pml and Egl, Minor Children v. State of Wyoming, Ex Rel. Department of Family Services" on Justia Law

An automobile accident in Idaho resulted in Emily Fairbanks receiving severe injuries while a passenger in a vehicle driven by Holly Galbraith. Fairbanks filed two lawsuits: one against the Idaho Transportation Department claiming negligent maintenance of a guardrail, and another against Galbraith in Wyoming for negligence. Galbraith sought to dismiss the Wyoming suit, citing that the statute of limitations had elapsed. The district court denied the motion. Later, Galbraith was granted summary judgment based on collateral estoppel, preventing relitigation of negligence and damages issues established in the Idaho case.Both parties appealed. Galbraith claimed the lower court had erred in its conclusion about the statute of limitations, while Fairbanks disputed the application of collateral estoppel and the application of Idaho's statutory cap on non-economic damages. The Supreme Court of Wyoming concluded that the statute of limitations had run before Fairbanks filed her complaint, reversing the district court's ruling on the issue. The court did not address the merits of the collateral estoppel appeal. The court found that under Idaho law, Fairbanks' lawsuit was time-barred as she made no effort to locate Galbraith during the time Galbraith was out of state, thus the statute of limitations was not tolled. View "Galbraith v. Fairbanks" on Justia Law

In this case heard by the Supreme Court of Wyoming, the appellant, Benjamin David Wilson, was charged with second-degree sexual abuse of a minor and third-degree sexual abuse of a minor, following allegations involving his stepdaughter, K.P. The jury acquitted him of the second-degree charge but found him guilty of the third-degree charge. Wilson appealed his conviction, arguing that the evidence presented was insufficient for a conviction on the third-degree charge.The facts presented to the court included K.P.'s testimony that Wilson had inappropriately touched her during a family event. Wilson denied the allegations, providing an alternative account of the incident. Despite this, the jury found him guilty of third-degree sexual abuse of a minor, leading to a sentence of 10 to 15 years in prison.In response to Wilson's appeal, the court affirmed the conviction. It stated that the jury's acquittal on one charge did not necessarily impact the verdict on the other charge. The court indicated that each charge was treated as a separate indictment, and verdicts on multiple charges did not need to be consistent. When reviewing the sufficiency of the evidence, the court considered the evidence in the light most favorable to the State, affirming Wilson's conviction based on K.P.'s testimony. View "Wilson v. State" on Justia Law

In this case, the Supreme Court of Wyoming heard an appeal by Rodger William Dillard, who contested the termination of his parental rights to his three minor children. Dillard had initially adopted his grandchildren after their biological parents' rights were terminated. After Dillard's wife, who had custody of the children, passed away, allegations of sexual abuse were made against Dillard by two of the children. Dillard was then charged with multiple counts of sexual abuse of a minor.The Department of Family Services initially aimed to reunify the children with Dillard. However, after more than a year in the Department's custody, the plan was changed to adoption due to Dillard's lack of progress in meeting the requirements of his Family Service Case Plan. Dillard was eventually sentenced to concurrent sentences of three to five years for two counts of sexual abuse of a minor. Following this, the Department filed a petition to terminate Dillard's parental rights.The district court found that termination was in the best interest of the children, as Dillard was unfit to meet their ongoing physical, mental, and emotional needs. Dillard appealed this decision, arguing that the Department had not made reasonable efforts to reunify him with the children.However, the Supreme Court of Wyoming affirmed the district court's decision to terminate Dillard's parental rights. The Court held that Dillard's incarceration due to his felony convictions for sexual abuse of a minor demonstrated his unfitness to have custody and control of the children. The Court therefore affirmed the termination of Dillard's parental rights under the provision of Wyo. Stat. Ann. § 14-2-309(a)(iv), which allows for termination of parental rights if the parent is incarcerated due to a felony conviction and is shown to be unfit for custody and control of the child. View "In re Termination of Parental Rights To: Mmd, Jid and Drd v. State, Ex Rel. Department of Family Services" on Justia Law

In a case certified by the United States District Court for the District of Wyoming, the Supreme Court of Wyoming was tasked with two questions regarding the duty of care owed by law enforcement officers to suspects while conducting an investigation.The first question asked whether a law enforcement officer acting within the scope of their duties owed a duty of care to the suspect(s) in a criminal investigation to conduct that investigation in a non-negligent manner. The court affirmed that law enforcement officers indeed owe such a duty, consistent with existing precedent.The second question asked whether, if a duty of care is owed, the law enforcement officer is entitled to assert qualified immunity under Wyoming law. The court affirmed that law enforcement officers are entitled to assert qualified immunity. Qualified immunity protects officers who act in good faith and whose actions are reasonable under the circumstances, and it serves important policy purposes, such as protecting law enforcement from the risk of being liable for mistakes made in the performance of their duties.The specific facts of the case involved a law enforcement officer who had received a tip about a suspected marijuana growing operation and subsequently initiated an investigation. The suspect, Deborah Palm-Egle, later filed a civil action against the officer and other parties, alleging a variety of tort claims. View "Palm-Egle v. Briggs" on Justia Law

During her employment as an administrative assistant, Judy Valencia suffered a right knee injury, which was covered by workers' compensation. Following the knee injury, she altered her gait and started experiencing pain in her left foot, ankle, and hammertoe. She sought workers' compensation benefits for these injuries, contending that they were causally related to her compensable right knee injury. However, the Wyoming Department of Workforce Services, Workers' Compensation Division denied the benefits, stating that the left foot, ankle, and hammertoe injuries were not related to the right knee injury. The Wyoming Medical Commission upheld the denial, and the district court affirmed the Commission's decision.In the Supreme Court, State of Wyoming, Valencia argued that her left foot, ankle, and hammertoe injuries either constituted a second compensable injury caused by her right knee injury or materially aggravated her preexisting left foot conditions. The court upheld the lower courts' decisions, finding that Valencia failed to meet her burden of proving either claim. The court noted that Valencia's treating physicians did not opine that her right knee injury or altered gait materially aggravated her preexisting left foot conditions. Additionally, the court found that an independent medical examiner's opinion, which stated that the right knee injury did not cause any temporary exacerbations or permanent material aggravation of Valencia's preexisting left foot conditions, was supported by substantial evidence. Therefore, the court affirmed the denial of workers' compensation benefits for Valencia's left foot, ankle, and hammertoe injuries. View "Valencia v. State of Wyoming, Ex Rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The case involves a dispute between the Teton County Assessor and Aspen S, LLC along with the Kelvin and Nancy Stirn Trusts. The landowners in Teton County contested the reclassification of their property from "agricultural" to "non-agricultural" by the Teton County Assessor. The Teton County Board of Equalization held a contested case hearing and found that the County Assessor's removal of the agricultural classification was incorrect. The County Assessor then appealed this decision to the State Board of Equalization.The State Board of Equalization consolidated the cases and sided with the County Assessor, stating that the County Board of Equalization had rejected the Assessor's determination without sufficient explanation. However, the State Board also assessed all the evidence independently and found that the taxpayers had not met their burden of proof. The landowners then sought judicial review of the agency's action in the district court, a portion of whose decision was adverse to the Teton County Assessor who now seeks further judicial review in the Supreme Court of Wyoming.The Supreme Court of Wyoming reversed and remanded the case, finding that the County Board of Equalization's decision lacked necessary findings of fact and conclusions of law as required by the Wyoming Administrative Procedure Act (WAPA). This lack of necessary findings and conclusions rendered the record insufficient for judicial review, causing the County Board of Equalization to act arbitrarily and capriciously. The case was remanded to the district court, with instructions to remand to the State Board of Equalization, which was instructed to remand to the Teton County Board of Equalization for findings and conclusions as required by WAPA. View "Teton County Assessor v. Aspen S, Llc" on Justia Law