Justia Wyoming Supreme Court Opinion Summaries

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The Supreme Court reversed the judgment of the Wyoming Oil and Gas Conservation Commission approving only one out of two applications filed by Exaro Energy III, LLC seeking the approval of adjacent drilling and spacing units (DSUs) in the Jonah Field, holding that the Commission's denial of Exaro's other application was arbitrary and capricious. At a contested case hearing the parties agreed that the evidence presented would apply to both applications. At the hearing's conclusion, the Commission found as to both applications that Exam had met its burden of proof and provided evidence satisfying the statutory requirements for the establishment of a DSU. However, the Commission approved one application and denied the other. The Supreme Court reversed in part, holding (1) substantial evidence supported the Commission's finding that Exaro's evidence satisfied the statutory requirements for establishment of a DSU in both applications; and (2) the Commission's decision to grant only one of the applications was arbitrary and capricious. View "Exaro Energy III, LLC v. Wyoming Oil & Gas Conservation Commission" on Justia Law

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In this personal injury action, the Supreme Court affirmed the judgment of the district court awarding Plaintiff damages and finding Ryan Gertsch to be seventy-five percent liable for Plaintiff's permanent injuries to her cervical and lumbar spine, holding that there was no prejudicial error in the proceedings below. Plaintiff was rear-ended first by Gertsch and then, fifteen months later, by James Frew. Plaintiff sued both Gertsch and Frew. Both defendants admitted negligence, and the jury awarded Plaintiff $10,000 in damages, finding Gertsch and Frew to be seventy-five percent and twenty-five percent responsible, respectively. The district court entered judgment in accordance with the jury's verdict. Plaintiff settled with Frew after the jury's verdict. Plaintiff appealed, raising arguments as to the judgment against Gertsch. The Supreme Court affirmed, holding (1) the district court erred in allowing Gretsch's Rule 35 examiner to testify despite Gertsch's failure to comply with Wyo. R. Civ. P. 26(a)(2)(B), but the admission of the examiner's testimony was harmless; (2) Gertsch's closing argument was not plainly erroneous; and (3) the district court did not err in requiring Plaintiff to disclose her substance abuse treatment records and in allowing them to be admitted at trial. View "Vahai v. Gertsch" on Justia Law

Posted in: Personal Injury
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In this inverse condemnation action the Supreme Court affirmed the decision of the district court entering judgment of a matter of law that Appellant failed to establish a taking and failed to provide proof of damages, holding that the trial court did not err in granting a directed verdict based on insufficient evidence of the value of Appellant's property. In her action, Appellant alleged that a road expansion project took a portion of her real property in Johnson County. The trial court entered a judgment as a matter of law, concluding that Appellant did not meet her burden to show that a taking occurred and that the evidence would be inadequate to prove any measure of damages for a partial taking. The Supreme Court affirmed, holding that the trial court properly entered a judgment as a matter of law that Appellant failed to establish a taking and failed to provide proof of damages. View "Byrnes v. Johnson County Commissioners" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree sexual abuse of a minor, holding that Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48. Defendant was charged with one count of first-degree sexual abuse of a minor. On April 9, 2018, the district court arraigned Defendant, starting the 180-day speedy trial clock. Defendant's trial, however, was not held within 180 days of his arraignment. Instead, Defendant's trial commenced on October 15, 2018, 190 days later. At issue was whether the district court properly continued the trial beyond the 180-day mandate of Rule 48(b). The Supreme Court affirmed, holding (1) the district court properly granted a continuance under Wyo. R. Crim. P. 48(b)(4)(A) even though Defendant did not agree to a continuance and the motion was not supported by a written affidavit; and (2) therefore, the ten-day continuance did not count toward the 180-day limit, and Defendant was not denied his right to a speedy trial. View "Flores-Gomez v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court granting summary judgment in favor of Defendants and dismissing Plaintiff's claims that Defendants violated various duties when drafting and administering a trust and preparing certain estate planning documents for Plaintiff, a beneficiary of the trust, holding that the district court did not err or abuse its discretion. Specifically, the Supreme Court held that the district court (1) did not err when it found Plaintiff failed to establish a material issue of fact showing that Defendants' actions damaged him; (2) did not abuse its discretion by denying Plaintiff leave to file a second amended complaint; and (3) did not err by concluding, as a matter of law, that Plaintiff violated the no-contest provision of the trust by bringing an action to void, nullify or set aside a provision of the trust. View "Gowdy v. Cook" on Justia Law

Posted in: Trusts & Estates
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The Supreme Court affirmed the order of the district court affirming the decision of the Board of Coroner Standards refusing to investigate the Teton County Coroner's alleged misconduct during a coroner's inquest, holding that the Board does not have the authority to review a complaint that a coroner failed to comply with the Board's standards dealing with the investigation of coroner cases. In a related action, the Supreme Court affirmed the district court's dismissal of an action seeking to set aside the coroner's inquest verdict in In re Birkholz, 434 P.3d 1102 (Wyo. 2019). While that action was pending, Plaintiffs requested that the Board investigate the coroner's alleged misconduct. The Board refused to investigate the inquest, concluding that it did not have the statutory authority to do so. The district court affirmed the Board's refusal to investigate. The Supreme Court affirmed, holding that the legislature did not authorize the Board to investigate a coroner's conduct during an inquest. View "Hayse v. Wyoming Board of Coroner Standards" on Justia Law

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The Supreme Court affirmed the order of the district court modifying custody, support and visitation awarding primary physical custody of the minor child to Father, holding that the district court did not abuse its discretion in denying a continuance of trial. After Mother's attorney was suspended from the practice of law the district court denied three separate pro se motions for continuance of trial. Following a trial, the district court found a material change of circumstances and awarded Father primary physical custody of the child, subject to visitation by Mother. The Supreme Court affirmed, holding that the trial court did not err in denying Mother's motion for continuance. View "Bacus v. Coon" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed the order of the district court terminating Mother's parental rights, holding that even if the district court erred in admitting Mother's physician's testimony and a related 2011 medical record, Mother was not prejudiced and the error was harmless. The jury found clear and convincing evidence for termination on grounds on two separate statutory grounds. Mother appealed, arguing that the district court abused its discretion when it admitted privileged evidence through her physician's testimony and an associated medical record. The Supreme Court affirmed, holding (1) there was ample evidence without the physician testimony and associated medical record to show that Mother was unfit to have custody and control of the child as required by Wyo. Stat. Ann. 14-2-309(a)(v); and (2) even assuming the testimony and medical record were privileged and the district court erred in admitting them, the error was harmless. View "Mets v. State, Department of Family Services" on Justia Law

Posted in: Family Law
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The Supreme Court affirmed Defendant's sentence imposed in connection with his conviction of domestic battery and failure to register as a sex offender, holding that the district court gave Defendant adequate credit for his presentence confinement. Pursuant to a plea agreement, Defendant pleaded guilty to domestic battery and failure to register as a sex offender. The court sentenced Defendant to a prison term of two to three years for the failure to register and a term of 180 days for the domestic battery, to run concurrently with each other and the sentence Defendant was already serving. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in denying Defendant's requested credit; and (2) because Defendant was not promised credit in addition to that to which he was entitled by law, he was not impermissibly induced to plead guilty, and his protected interest in the credit was not affected. View "Petersen v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's convictions of aggravated assault and battery, domestic battery, strangulation of a household member, violating a protective order, and witness intimidation, holding that there was one trial error in a single incident of prosecutorial misconduct, but Defendant suffered no prejudice from the comment. Specifically, the Court held (1) the district court did not err in denying Defendant's motion for a new trial based on the State's alleged failure to disclose exculpatory evidence; (2) the district court did not err in denying Defendant's motion for a new trial based on claims of ineffective assistance of counsel; (3) the State committed prosecutorial misconduct by vouching for the credibility of the victim, but the comment was not prejudicial; (4) the district court did not err in joining charges against Defendant for trial; (5) the district court did not err in denying Defendant's motion for a Daubert hearing on the testimony of the State's domestic violence expert; and (6) cumulative error did not warrant reversal of Defendant's conviction. View "Byerly v. State" on Justia Law