Justia Wyoming Supreme Court Opinion Summaries

After being arrested during a traffic stop in April 2024, the defendant faced multiple criminal charges in Laramie County, Wyoming. At the time, he was already on probation for prior misdemeanor offenses and had an outstanding warrant in a separate felony case. Following the arrest, he was charged with new felonies and misdemeanors, and his probation was eventually revoked, resulting in the imposition of the underlying misdemeanor sentence. Over the subsequent months, he remained in custody at various points for reasons including probation violations and failure to appear, and he ultimately entered guilty pleas to select charges in two felony cases pursuant to a plea agreement.The District Court of Laramie County, after accepting the plea agreement, sentenced the defendant to concurrent terms of imprisonment on the felony charges. At sentencing, the parties disputed the amount of credit for presentence confinement to be applied to his sentences. The State argued that he was entitled only to credit for days spent in custody after completion of his misdemeanor sentence, while the defendant sought credit for nearly all days spent in custody between his arrest and sentencing. The district court initially awarded 56 days of credit, later increasing this to 64 days after further argument, but declined to grant additional credit for periods during which the defendant was serving his misdemeanor sentence.The Supreme Court of Wyoming reviewed the legality of the sentence, specifically the award of credit for presentence confinement. The court held that, under Wyoming precedent, a defendant is only entitled to credit against concurrent sentences in separate cases for time spent in custody if that confinement was due solely to a financial inability to post bond. Because the defendant was in custody for probation revocation and serving a sentence in another case, rather than solely due to an inability to post bond, he was not entitled to additional credit. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Gauna v. State" on Justia Law

Law enforcement agents in Rawlins, Wyoming, surveilled suspects believed to be involved in drug distribution. During this operation, officers observed two known drug users at the residence of an individual who was not originally a target. After one of these individuals left, she was stopped for a traffic violation, and a drug detection dog conducted a search but found no contraband. Subsequently, officers followed the resident, observed him commit a traffic violation, and conducted a traffic stop. During the stop, a drug detection dog alerted to the presence of drugs in the vehicle, leading to a search that recovered significant quantities of methamphetamine, marijuana, and a firearm. Additional evidence was found at the individual's home and on his person. He was charged with multiple drug and firearm offenses and misdemeanors.The District Court of Carbon County conducted pretrial hearings on the admissibility of evidence, including evidence under Wyoming Rule of Evidence 404(b) and the validity of the traffic stop. The district court admitted text and Facebook messages between the defendant and various individuals, which referenced drug activity using coded language, concluding they were relevant to the charges and their probative value was not substantially outweighed by unfair prejudice. The court denied the defendant’s motion to suppress the evidence from the traffic stop, finding reasonable suspicion existed, and later denied a request to file a late motion to suppress related to the drug dog’s alert. At trial, the jury convicted the defendant on most charges, and the district court imposed sentences accordingly.On appeal, the Supreme Court of Wyoming considered whether the defendant had waived his right to challenge the dog sniff and whether the district court erred in admitting the 404(b) evidence. The court held that the defendant waived his challenge to the dog sniff by failing to raise it in a timely manner and did not demonstrate good cause for this failure. Additionally, the court found no abuse of discretion in admitting the messages, concluding the district court properly applied the required evidentiary framework. The Supreme Court of Wyoming affirmed the convictions. View "Brown v. The State of Wyoming" on Justia Law

Cowboy Racing was formed in Wyoming with two members: EFTI, which held a 51% interest and was managed by William Edwards, and Dillinger’s, with a 49% interest, managed by Ryan Clement. The company’s operating agreement appointed Edwards and Clement as the initial managers and set out procedures for removing a manager, including both a for-cause provision and a mechanism for removal with the consent of a majority interest. In February 2025, EFTI, holding the majority interest, removed Clement as a manager citing his unauthorized expenditures. Despite his removal, Clement continued to act as though he had authority on behalf of Cowboy Racing.EFTI and Cowboy Racing then filed suit in the District Court of Laramie County, seeking a declaration that Clement could not act on behalf of the company, enforcement of a purchase right under the operating agreement, damages for breach of a letter of intent, and, relevant here, a preliminary injunction to prevent Clement from representing himself as a manager. Clement objected, arguing that the removal process was procedurally and substantively improper and conflicted with the operating agreement.The Supreme Court of the State of Wyoming reviewed the district court’s grant of the preliminary injunction, applying an abuse of discretion standard. The Court held that while the district court’s order was inartfully phrased as a final determination, it properly found that Cowboy Racing and EFTI were likely to succeed on their claim that Clement was lawfully removed under the operating agreement. The Court concluded the agreement was unambiguous and that EFTI, as the majority member, had the authority to remove Clement with express written consent. The preliminary injunction was affirmed, but the parties retain the right to present further evidence at trial on the merits. View "Dillinger's LLC v. CR-GTD, LLC" on Justia Law

A man and his wife experienced a tumultuous marriage marked by frequent conflict and the issuance of mutual protection orders. The couple eventually separated, and the wife, along with their children, moved out. During and after their separation, the husband violated a modified protection order that restricted his contact with his wife to matters relating to their children and prohibited any abuse or conduct likely to cause her fear. The state filed two sets of criminal charges against the husband, including witness intimidation, stalking, and multiple counts of violating a protection order. The cases were joined for trial. Evidence presented at trial included numerous communications from the husband to his wife, some of which the wife described as threatening or emotionally distressing.The District Court of Uinta County presided over the trial. The court excluded certain evidence regarding the wife’s past conduct, deeming it irrelevant or more prejudicial than probative, and limited the admissibility of other evidence on similar grounds. A jury acquitted the husband on two counts of violating a protection order but convicted him on all remaining charges. The district court orally sentenced the husband to specific jail terms but entered written sentencing orders that were inconsistent with the oral pronouncement, including indeterminate sentences for misdemeanors and conflicting statements about the order in which sentences would be served.The Supreme Court of Wyoming reviewed the case. It held that the district court did not abuse its discretion by excluding most evidence of the wife’s conduct, finding such evidence irrelevant to the husband’s specific intent or the elements of the crimes charged, and that the exclusion did not violate his constitutional rights. The court also held that the evidence was sufficient to support the witness intimidation conviction, as the husband's statements constituted threats under the statute. However, it found that the written sentencing orders imposing indeterminate misdemeanor sentences were illegal and that the chronological order of sentences was unclear. The court affirmed the convictions but reversed and remanded for correction and clarification of the written sentencing orders. View "Walker v. The State of Wyoming" on Justia Law

A young child, TF, was using the men’s restroom at a Walmart when James Neil Todd entered. Shortly after, TF told his mother that Mr. Todd had asked him if he wanted to touch Mr. Todd’s “wiener” while Mr. Todd’s penis was exposed. The mother reported the incident to store staff and police. Mr. Todd was quickly located by law enforcement, and he admitted his penis was exposed in the restroom but denied asking the child to touch it, instead claiming the child may have misunderstood the situation due to an urgent need to urinate. The State charged Mr. Todd with attempted sexual exploitation of a child, alleging he knowingly attempted to entice TF to engage in explicit sexual conduct by exposing his penis and asking TF if he wanted to touch it.The District Court of Campbell County held a jury trial, where the jury found Mr. Todd guilty. Mr. Todd was sentenced to a prison term, suspended in favor of jail time and supervised probation. On appeal to the Supreme Court of Wyoming, Mr. Todd argued there was insufficient evidence to support his conviction and that the district court erred in refusing to give a jury instruction defining “lascivious.”The Supreme Court of Wyoming affirmed the conviction. The Court held the evidence was sufficient for a reasonable jury to conclude Mr. Todd took a substantial step toward causing, inducing, or enticing a child to engage in explicit sexual conduct, specifically masturbation, as defined by statute. The Court also held that the district court did not abuse its discretion by declining to give Mr. Todd’s proposed jury instruction defining “lascivious,” as the State was not required to prove a lascivious exhibition to sustain the conviction and the term should be given its ordinary meaning. The judgment of the district court was affirmed. View "Todd v. The State of Wyoming" on Justia Law

A man and a woman began a relationship in 2015 and had a child in 2018. Though they were never married, they lived together until 2024. After their separation, they informally shared custody of their child, alternating time with her. In 2025, the mother unilaterally moved to Colorado with the child, initially telling the father it was a temporary visit but intending to relocate permanently. The father responded by filing for custody, visitation, and child support, and sought emergency temporary custody due to the mother’s relocation. Both parents accused each other of substance abuse but drug tests were negative.The District Court of Park County held hearings and initially awarded temporary physical custody to the mother and joint legal custody to both parents, with regular drug testing and structured visitation for the father. At a subsequent bench trial, the court continued physical custody with the mother pending a final order. Ultimately, in its final order, the court found both parents fit and competent, but awarded the mother primary physical custody, citing the child’s enrollment in school in Colorado and the stability of the mother’s home as serving the child’s best interests. The father was granted substantial visitation, including four consecutive nights each month, alternating holidays, and eight weeks each summer. The court declined to award child support to either party because of the father’s travel costs.On appeal, the Supreme Court of the State of Wyoming reviewed the district court’s custody order for abuse of discretion. The Supreme Court affirmed the district court’s decision, holding that the district court did not abuse its discretion in awarding the mother primary physical custody. The Supreme Court found the district court’s findings were supported by the record and that its decision reasonably balanced the child’s best interests and the practical challenges posed by the parents’ geographic separation. View "Swindler v. Bright" on Justia Law

Paul Sorum and Jeff Martinson, as co-owners of Clean Crude, entered into written lease agreements with Big Sky Limited of Wyoming for the rental of several aboveground oil storage tanks. After Clean Crude failed to make required lease payments and left the tanks in poor condition, Big Sky sued Clean Crude, Sorum, and Martinson, seeking damages for breach of contract and related claims. Martinson ultimately settled, and Mike Sikorski, having acquired Big Sky’s interest, was substituted as plaintiff. During a bench trial, Sikorski testified that Sorum and Martinson personally guaranteed payment of the leases if Clean Crude could not pay, but Sorum was not allowed to testify about the alleged oral guarantee.The District Court of Campbell County found Clean Crude liable for breach of the lease agreements and found Sorum personally liable for damages based on the oral guarantee. The court initially awarded damages, but Sorum appealed, and the Wyoming Supreme Court, in Sorum v. Sikorski, 2024 WY 124, reversed in part and remanded solely to allow Sorum to testify regarding the alleged oral guarantee. On remand, the district court restricted evidence to the issue of the oral guarantee, allowed Sorum to testify, and reaffirmed its finding that Sorum had made and breached a personal oral guarantee, awarding the same damages.The Supreme Court of Wyoming reviewed the district court’s actions on remand, holding that the district court properly limited the scope of evidence to the oral guarantee, consistent with the mandate rule and law of the case doctrine. The Supreme Court further held that the district court did not clearly err in finding that Sorum made an enforceable oral guarantee to pay the leases with personal funds and breached that guarantee. The Supreme Court affirmed the district court’s judgment in its entirety. View "Sorum v. Sikorski" on Justia Law

Several years after a car accident in January 2015, Samantha Ritter brought a lawsuit against William Lopez for damages. Ritter attempted to serve Lopez at the address listed in the accident report, but the Campbell County Sheriff’s Office determined that the property was vacant and could not locate him. Ritter then pursued substituted service under Wyoming’s nonresident motorist statute, which involved serving the Secretary of State and mailing the summons and complaint to Lopez’s last known address. Despite multiple efforts—including contacting his insurer, making phone calls, and hiring a search service—Ritter was unable to find a current address for Lopez.After Lopez failed to respond, Ritter sought and was granted default judgment in the District Court of Campbell County. The case was later dismissed without prejudice for failure to prosecute, but the district court reinstated the matter upon Ritter’s motion under Wyoming Rule of Civil Procedure 60. After a hearing, the district court entered default judgment in Ritter’s favor and awarded her damages. Lopez’s subsequent Rule 60 motion to set aside the default judgment was denied, and he appealed.The Supreme Court of the State of Wyoming held that Lopez waived his challenge to the sufficiency of service and due process on appeal because he had not raised those issues below, except for the jurisdictional question of due diligence required for substituted service. The court found that Ritter had exercised sufficient due diligence to serve Lopez under the statute and that personal jurisdiction was properly established. The court also determined it lacked jurisdiction to review the reinstatement of the case because Lopez’s notice of appeal did not specify that order. Finally, the court concluded that the district court did not abuse its discretion in denying Lopez’s Rule 60 motion. The decision was affirmed. View "Lopez v. Ritter" on Justia Law

The appellant and the victim were involved in a long-term romantic relationship that had deteriorated before the incident. On May 24, 2023, the two met at a convenience store in Rock Springs, Wyoming, to exchange personal items. An argument ensued and escalated, moving across several locations. The appellant maintained that after the victim threw a motorcycle part through her vehicle’s rear window, she tried to drive away and struck him unintentionally as he ran in front of her vehicle. She then transported him to a hospital, where he later died from his injuries. Initially charged with involuntary manslaughter, the charges were amended to include second-degree murder and aggravated vehicular homicide based on further investigation.The District Court of Sweetwater County presided over a four-day jury trial, during which the State presented evidence including the appellant’s statements to law enforcement, surveillance footage, accident reconstruction testimony, and communications showing a deteriorating relationship. The appellant was found guilty of second-degree murder and sentenced to forty-five years to life. After sentencing, she filed a motion for a new trial under Rule 21 of the Wyoming Rules of Appellate Procedure, claiming ineffective assistance of counsel based on several alleged failures by her trial attorney. The district court denied the motion without holding a hearing, concluding she had not shown either deficient performance or prejudice.The Supreme Court of the State of Wyoming reviewed the case. Applying the two-prong test from Strickland v. Washington, the court held that, even assuming counsel’s performance was deficient, the appellant could not establish prejudice because substantial independent evidence supported the jury’s verdict. The court found that the outcome of the trial would not have been different even if the challenged evidence had been excluded. Thus, the Supreme Court of Wyoming affirmed the district court’s denial of the motion for a new trial. View "Daniels v. State" on Justia Law

A married couple separated after the husband made a substantial prepayment to the IRS for their 2021 tax liability. Both parties subsequently filed separate tax returns for that year, and the tax preparer allocated the prepayment to the wife’s return. While the divorce proceedings were ongoing, the husband sought a court order to reallocate the prepayment. In February 2023, the District Court of Campbell County ordered the parties to file an amended joint tax return for 2021 and held them jointly and severally liable for any tax assessments related to that return. Despite this order, the couple’s tax preparer filed both a joint return and an amended individual return for the husband on the same day, which led to confusion and complications with the IRS regarding the prepayment.Following the entry of the divorce decree, which incorporated the court’s prior directives, the wife moved for an order to show cause, alleging the husband had not complied with the requirement to file a joint return. An evidentiary hearing was held, during which the court found the husband’s testimony regarding his conduct not credible and determined he had willfully frustrated the completion of the joint return by filing an amended individual return. The court ordered the husband to withdraw all other tax returns for 2021 except the joint return and to pay penalties and interest resulting from delays.The Supreme Court of Wyoming reviewed the case, applying an abuse of discretion standard and examining whether the district court’s findings were clearly erroneous. The court affirmed the lower court’s contempt order, holding that the district court did not err in its timing determination, did not abuse its discretion in finding contempt, and did not exceed the scope of the decree by ordering withdrawal of returns or monetary sanctions. The court concluded that the husband willfully disobeyed a clear court order and failed to prove inability to comply. View "Morrison v. Hinson-Morrison" on Justia Law