Justia Wyoming Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of attempted aggravated robbery, holding that the district court did not commit judicial misconduct or deprive Defendant of a fair trial by commenting on the foundation for admission of the gun used in the robbery and did not abuse its discretion by denying Defendant's motion for a mistrial.On appeal, Defendant argued that the district court committed misconduct by explaining to the State how to lay the foundation for admission into evidence of the gun and erred by denying his motion for a mistrial after the State elicited an answer from a witness in violation of an order in limine. The Supreme Court affirmed, holding (1) the district court did not deprive Defendant of a fair trial; and (2) although the witness's testimony violated the order in limine the district court properly concluded that the error was not so prejudicial that it denied Defendant a fair trial. View "Langley v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' complaint under Wyo. R. Civ. P. 12(b)(6) and (c), holding that the district court did not err.Plaintiffs sued Defendants asserting claims for defamation per se, tortious interference with a prospective economic advantage and business expectancy, and false light invasion of privacy. The district court dismissed all claims. The Supreme Court affirmed, holding (1) Plaintiffs did not state claims for defamation per se; (2) Plaintiffs could not recast their second cause of action as a claim for prima facie tort; and (3) Plaintiffs did not state a claim for false light invasion of privacy. View "Bextel v. Fork Road LLC" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated felony child abuse, holding that the district court did not err in admitting Wyo. R. Evid. 404(b) evidence from misconduct that was originally charged but dismissed by the circuit court.Defendant was convicted of inflicting injuries on a minor child, PS on November 2 and November 3, 2018. On appeal, Defendant argued that the district court erred in admitting evidence related to an incident on September 10, 2018, in which Defendant admitted that he threw a bottle at PS and bruised her head. Specifically, Defendant argued that it was improper to admit the evidence under Wyo. R. Evid. 404(b) because the evidence related to a charge dismissed at the preliminary hearing. The Supreme Court disagreed, holding that the district court did not err in admitting the evidence surrounding the September 10, 2018 incident. View "Putnam v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of possession of methamphetamine, possession with intent to deliver methamphetamine, and conspiracy to deliver methamphetamine, holding that the district court did not err in denying Defendant's motion to suppress.After Wyoming Division of Criminal Investigation agents gathered information that Defendant was selling methamphetamine they installed a GPS tracking device on his truck. Wyoming Highway Patrol Troopers initiated a traffic stop of Defendant based on a crack in the front windshield of his truck. After a search, drugs and drug paraphernalia were discovered. Defendant moved to suppress, which the trial court denied. The Supreme Court affirmed, holding that the Troopers had reasonable suspicion to stop the truck for driving with a crack within the front windshield. View "Simmons v. State" on Justia Law

The Supreme Court reversed the judgment of the district court denying Steven Mitchell's motion for a sentence reduction as untimely, holding that the district court erred in denying Mitchell's motion as untimely.Defendant pled no contest to one count of felony interference with custody. The district court sentenced Defendant to three and one-half years in prison. Defendant later filed a pro se Wyo. R. Crim. P. 35(b) motion for reduction of his sentence. The district court issued an order denying the motion as untimely. The Supreme Court reversed and remanded the case to the district court for a ruling on the merits, holding that the district court erred in denying the motion as untimely and that the error was not harmless. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the district court's denial of a motion to set aside default judgment against it after it failed to answer a writ of garnishment, holding that, despite certain procedural infirmities, the district court did not err in denying the motion to set aside default judgment.After Monty Elliott obtained a judgment his efforts to collect led to a writ of garnishment of Sonny Pilcher's earnings from Rack's Gentlemen's Club, a business operated by CC Cowboy's Inc. The district court entered default judgment against CC Cowboys. Pilcher filed a motion to vacate default judgment, which the district court denied. The Supreme Court affirmed, holding that CC Cowboys waived its objection to personal jurisdiction by appearing in the proceeding without making that objection. View "Pilcher v. Elliott" on Justia Law

The Supreme Court remanded this case to the district court with instructions to determine whether excusable neglect extended Plaintiff's time to file the petition for review of the decision of the Office of Administrative Hearings (OAH) concluding that Plaintiff's infection was not compensable, holding that the record did not reveal whether the district court considered the question of excusable neglect.Plaintiff scraped his knuckle on a locker as he was getting ready to leave a trona mine, where he worked. The scrape developed necrotizing fasciitis, causing serious injuries. The Department of Workforce Services, Workers' Compensation Division, deemed Plaintiff's injury compensable. The OAH served an order concluding that Plaintiff's injuries were not compensable. The district court reversed, concluding that Plaintiff's infection was compensable. Plaintiff's employer appealed, arguing that the district court lacked jurisdiction because the petition for judicial review was untimely filed. The Supreme Court remanded the case for the limited purpose of determining whether excusable neglect extended the time for filing a petition for review. View "Tata Chemicals Soda Ash Partners, Ltd v. Vinson" on Justia Law

The Supreme Court dismissed this appeal from the decision of the district court reversing the decision of the director of the Wyoming Department of Environmental Quality (WDEQ) and the Environmental Quality Council (EQC) denying Brook Mining Company's application for a permit to develop and operate a new surface coal mine, holding that the issues presented in this appeal were moot.The EQC concluded that the permit application was deficient and denied Brook Mining Company's application. The Director of the WDEQ then denied the permit. The district court reversed. While this appeal was pending, Brook Mining Company submitted a revised permit application. The Director issued a decision that approved the revised permit application. Also while the appeal was pending, the legislature changed the regulatory structure for the approval of new coal mine applications by removing the opportunity for an EQC contested case hearing prior to the Director's decision. The Supreme Court dismissed the appeal, holding that the issues in this appeal do not continue to present a justiciable controversy and have thus become moot. View "Fisher v. Wyoming Department of Environmental Quality" on Justia Law

The Supreme Court affirmed the decision of the district court using a judgment against Alexander Mantle to set off judgments Alexander and Majorie Mantle had against Ray and Gary Garland and failing to recognize the Mantles' right to the proceeds from a settlement of a third-party action against Karl Killmer and Killmer & Associates (collectively, Killmer), holding that the district court did not err.Specifically, the Supreme Court held (1) Ray and Gary were entitled to use the assigned portions of the judgment against Alexander to satisfy the judgments the Mantles had against them for fraudulent transfers; and (2) the district court did not have jurisdiction to the portion of the Killmer settlement funds not deposited with the district court. View "Mantle v. North Star Energy & Construction LLC" on Justia Law

The Supreme Court affirmed the decision of the district court granting Goshen County Fairgrounds summary judgment on its assertion of governmental immunity and dismissing Plaintiff's negligence action, holding that Plaintiff did not establish a genuine issue of material fact that would preclude summary judgment on the basis of the Fairgrounds' immunity.Plaintiff fell at an event held in one of the Goshen County Fairgrounds' buildings. Plaintiff filed a complaint against Goshen county, the State, and the Fairgrounds, alleging negligence. The district court granted summary judgment for the Fairgrounds. The Supreme Court affirmed, holding that disputed issues of material fact did not exist so as to preclude summary judgment on the question of whether the Fairgrounds and its employees were negligent in the operation or maintenance of the building. View "Varela v. Goshen County Fairgrounds" on Justia Law