Justia Wyoming Supreme Court Opinion Summaries

The case arose after the Wyoming Legislature amended the election code to require voters who wished to change their party affiliation before a primary election to do so at least 96 days prior to the primary. Several individuals were affected by this new deadline: some were unable to vote for their preferred candidates in the 2024 primary because they could not change party affiliation after the cutoff, while others, who ran for office, were unsuccessful in their respective primaries. The plaintiffs challenged the constitutionality of the 96-day party affiliation deadline, arguing it violated their rights under the Wyoming Constitution to open, free, and equal elections, untrammeled exercise of suffrage, and equal political rights.The District Court of Laramie County granted summary judgment in favor of the Secretary of State, holding that the statutes establishing the 96-day party affiliation deadline were a valid exercise of legislative authority to regulate elections and did not violate constitutional voting rights or equal protection. The plaintiffs appealed only the district court’s ruling on the party affiliation deadline.The Supreme Court of Wyoming reviewed the case de novo, considering only legal questions as the facts were stipulated. The Court held that the right to vote in Wyoming, including in primary elections, is fundamental, but that the legislature is also constitutionally charged with securing the purity of elections. Employing a balancing approach informed by the Anderson-Burdick standard, the Court found the 96-day deadline imposed only a slight burden on voting rights, justified by the state’s legitimate interest in preventing party raiding and ensuring orderly elections. The Court further held that the deadline did not violate equal protection, as all electors had an equal opportunity to affiliate before the cutoff, and distinctions drawn between new registrants and previously registered voters were not constitutionally impermissible. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Malcom v. Gray" on Justia Law

The parties in this case were married from 1998 until their divorce in 2025. During the marriage, the wife acquired thirty shares in her employer’s business, Plan One Architects, after the couple jointly decided to invest. The shares were purchased using loans from the husband’s mother, refinancing their home, and selling a car. Plan One’s bylaws require only employees to hold shares, so the wife solely owns them and must sell them back to the company when her employment ends. The value of the shares primarily comes from annual shareholder distributions, which comprise most of the wife’s income.The District Court of Park County held a bench trial to resolve disputes over the division of the Plan One shares and associated debts. It found the shares to be marital property acquired during the marriage, largely due to the wife’s loyalty to her employer and financial support from the husband’s mother. The court ordered the wife to pay the husband one-half of the annual distributions from the shares, minus associated taxes, until her employment ends. Additionally, the court required both parties to equally repay the outstanding loans to the husband’s mother. Upon the wife's eventual sale of the shares, she must pay the husband one-half of the sale proceeds, minus capital gains taxes.On appeal, the Supreme Court of Wyoming reviewed whether the district court erred in awarding the husband half of the distributions, assigning tax liability to the wife, and directing repayment of the debt to the husband’s mother. The Supreme Court held that the shares were a vested marital asset and affirmed the district court’s discretion in awarding the husband periodic property distribution payments, assigning tax responsibility to the wife, and dividing the marital debt. The district court’s decree was affirmed. View "Atkinson v. Atkinson" on Justia Law

Law enforcement responded to a welfare check at a hotel where a mother and her two young children were staying. Upon investigation, officers discovered evidence of methamphetamine use and poor living conditions, including malnutrition and neglect of the children. The children were taken into protective custody, and the mother was arrested and charged with endangering children. During the dependency proceedings, the mother gave birth to a third child, who was also removed after testing positive for methamphetamine at birth. Over the next two years, the mother struggled with housing instability, inconsistent visitation with her children, repeated incarceration, and ongoing substance abuse.The State of Wyoming, through the Department of Family Services (DFS), filed neglect and later termination petitions in the District Court of Fremont County. The mother participated in case planning and received services but failed to meet critical goals, such as obtaining safe housing, maintaining sobriety, and engaging consistently with her children. The district court conducted a bench trial and, after considering evidence of the mother’s continued substance abuse, incarceration, and inability to care for the children, terminated her parental rights under Wyoming Statute §§ 14-2-309(a)(iii) and (a)(v). The court found that DFS made reasonable efforts to reunify the family and that termination was in the children’s best interests.The Supreme Court of the State of Wyoming reviewed the case, applying a strict scrutiny standard and examining whether the evidence supported termination under either statutory ground. The court held that DFS’s procedural shortcomings did not prevent the mother from understanding or completing her case plan and distinguished this situation from MB v. Laramie County Department of Family Services, 933 P.2d 1126 (Wyo. 1997). Because the mother failed to challenge termination under § 14-2-309(a)(v), the court affirmed the district court’s decision to terminate her parental rights on that independent ground. View "In re Termination of Parental Rights To: BAC II" on Justia Law

A sixteen-year-old girl, after suffering a rape, was admitted to an adolescent psychiatric unit for mental health treatment. While in the facility, she alleged that another patient, Z.L., touched her buttocks with his foot and later, while she was awake, put his hand down her pants and touched her vagina. The incident allegedly occurred in a common room under indirect staff supervision. After reporting the event and undergoing a sexual assault exam, she was discharged from the facility three days later. Her co-conservators filed a medical malpractice action against the health facility, claiming that inadequate supervision enabled the alleged assault and caused her further harm.The matter proceeded to a seven-day jury trial in the District Court of Campbell County. The court approved a special verdict form with a threshold question asking whether Z.L. “inappropriately touched” the plaintiff; the form did not define this term. The jury answered the question in the negative and returned a verdict for the defendant hospital. The plaintiffs objected to the structure of the verdict form and the absence of a legal definition for “inappropriate touch.” They moved for a new trial, which was denied, and the court awarded costs to the defendant after finding the plaintiffs’ objections to costs untimely.The Supreme Court of Wyoming reviewed the case. It held that the plaintiffs had properly preserved their objections for appeal, but found no error in the special verdict form or jury instructions, concluding that the language used was consistent with the evidence and arguments presented. The court determined the district court did not abuse its discretion in responding to jury questions, denying a new trial, or awarding costs. The Supreme Court affirmed the judgment, denial of a new trial, and the award of costs. View "Rose v. Campbell County Health" on Justia Law

A child, BEP, was born in November 2022 and soon after was hospitalized due to breathing difficulties and low weight, leading to concerns about his mother’s ability to care for him. The mother had inappropriately watered down formula and given BEP medicine unsuitable for his age. As a result, BEP was placed in protective custody and later foster care under the Wyoming Department of Family Services (Department), while paternity was being established. The Department identified Skylar Colten Remer as BEP’s legal father in May 2023 and developed a case plan to help him establish a safe relationship with BEP, which included counseling, supervised visitation, and parenting coaching. Despite these efforts, the Department found Father did not engage in the services provided, failed to demonstrate meaningful change, and was unable to provide basic or higher-level care for BEP, who had significant behavioral and emotional needs.The Department petitioned the District Court of Natrona County to terminate Father’s parental rights under Wyo. Stat. Ann. § 14-2-309(a)(iii) and (v), citing Father’s neglect, instability, and lack of engagement. Father failed to timely respond to the petition, resulting in a default being entered against him. At the subsequent termination hearing, Father could cross-examine witnesses but could not present his own evidence. The district court found clear and convincing evidence supporting termination on both statutory grounds and concluded termination was in BEP’s best interest.On appeal, the Supreme Court of Wyoming reviewed whether sufficient evidence supported the district court’s decision. The Court held that clear and convincing evidence established that BEP had been in foster care for the required period and that Father was unfit to have custody and control of BEP, as required by Wyo. Stat. Ann. § 14-2-309(a)(v). The Supreme Court of Wyoming affirmed the district court’s termination of Father’s parental rights. View "In the Matter of the Termination of Parental Rights To: BEP" on Justia Law

A landowner sought to establish a private road across a neighboring ranch property to access an isolated parcel it owns, which is largely surrounded by the neighbor’s land. The landowner made unsuccessful attempts to negotiate an easement, then filed a petition under Wyoming’s private road statute to secure access. The parcel in question lacks legally enforceable vehicle access except through the neighbor’s land. Various options for routes, including one passing through public land, were considered, but physical and legal barriers precluded public access.The District Court of Albany County held a bench trial, appointed viewers and appraisers to review potential routes, and ultimately established a private road along the landowner’s proposed route, finding it to be the most reasonable and convenient. The court awarded damages to the neighbor based on a “before and after” appraisal, and imposed several conditions on the private road. The landowner appealed three of those conditions, while the neighbor cross-appealed, challenging the findings of good faith, necessity, route selection, damages, and denial of an agricultural-use-only restriction.The Supreme Court of Wyoming affirmed the district court’s findings of good faith, necessity, route selection, and damages, as well as its rejection of the agricultural-use-only restriction. The court concluded that the parcel was landlocked and that neither the purported public land route nor alternative bypasses provided legally enforceable access. It found the chosen route was most reasonable and convenient and that damages were properly calculated. However, the Supreme Court reversed two conditions imposed by the district court—specifically, the requirement that the landowner repair any damage regardless of fault, and the restriction on vehicles with more than four axles—because they were not supported by evidence. The remaining challenged condition and the denial of the agricultural-use-only restriction were affirmed. View "Wagonhound Land & Livestock Company, LLC v. Little Medicine Creek Ranch, Inc." on Justia Law

The appellant owns a one-story home in Laramie County, Wyoming. In April 2024, the Laramie County Assessor valued her property at $188,822. After the appellant objected, field appraisers inspected the home, which led to a series of adjustments, ultimately lowering the valuation to $164,939. Throughout these valuations, the home’s condition was rated as “average” and its quality as “low.” The appellant contended that her home’s value should be reduced further, citing its age, lack of updates, limited livable space, and certain deficiencies such as a non-livable basement and outdated construction features.Following an appeal by the appellant, the Laramie County Board of Equalization held a contested hearing. The appellant presented evidence including her home’s purchase price, its physical shortcomings, and comparisons to other neighborhood homes. The Board heard testimony from the Assessor regarding the process for property valuation and the guidelines for assigning condition ratings. Despite the field appraisers’ assessment, the County Board, by a 3-2 vote, determined that the condition should be downgraded from “average” to “fair” and remanded the matter to the Assessor for reclassification. The Board based its decision on limited photographic evidence and the appellant’s testimony.The Assessor appealed to the Wyoming State Board of Equalization, which reversed the County Board’s decision, finding it was not supported by substantial evidence. The district court affirmed the State Board. On further appeal, the Supreme Court of Wyoming reviewed only the County Board’s decision. The Supreme Court held that the County Board’s determination to downgrade the property’s condition was not supported by substantial evidence, as the appellant did not present credible evidence sufficient to rebut the presumption in favor of the Assessor’s valuation. The Supreme Court reversed the County Board’s decision. View "Gummel v. Laramie County Assessor" on Justia Law

Wyoming’s Constitution requires the legislature to provide a thorough and efficient education for all students. Historically, public education was funded by local property taxes, resulting in significant disparities between districts. Decades of litigation and legislative reform led to a statewide, cost-based funding model for school operations and facilities. This model, known as the legislative model (LM), was intended to ensure equal educational opportunities by using a block grant system based on the estimated cost of an adequate education (the “basket of goods and services”). Periodic recalibrations and annual adjustments for inflation were required to keep the model current.The plaintiffs, including the Wyoming Education Association and several school districts, sued in 2022, alleging that the legislature’s funding model was no longer cost-based, wasn’t properly adjusted for inflation, and lacked funding for certain innovations such as elementary school counselors, nutrition services, and school resource officers. They also claimed the State’s facilities oversight was inadequate. The District Court of Laramie County, after a bench trial, found in favor of the plaintiffs on all issues, concluding that the legislature failed to fund actual costs, address inflation, and include necessary innovations, and that the State’s facilities process was constitutionally deficient.The Supreme Court of Wyoming reviewed the case. The Court affirmed the district court’s findings that the legislature violated students’ equal protection rights by failing to fund the true cost of teacher salaries and by not properly adjusting for inflation. However, it reversed the requirement to fund a one-to-one technology ratio, nutrition services, and school resource officers, finding insufficient evidence that these innovations required statewide funding. The Court also reversed the order requiring statewide assessment of educational suitability for facilities, holding the State’s administrative process was constitutionally adequate. The Court ended the lower court’s retention of jurisdiction, assuming the legislature would act in good faith to comply with constitutional requirements. View "The State of Wyoming v. Wyoming Education Association" on Justia Law

The appellant was charged with conspiracy to deliver fentanyl in Natrona County, Wyoming. Before he could be arrested in Wyoming, he traveled to Iowa, where he was apprehended after committing additional criminal offenses involving fleeing from police. He was incarcerated in Iowa for 259 days pending resolution of those Iowa charges. After pleading guilty and receiving probation in Iowa, he became available for extradition to Wyoming, where he was ultimately convicted and sentenced to prison. He requested credit toward his Wyoming sentence for the entire period of Iowa incarceration, arguing that his Iowa confinement was caused by the Wyoming charges.In the District Court of Natrona County, the judge awarded the appellant 307 days of credit, starting from the date the Iowa charges were resolved and he became available for extradition to Wyoming, until his Wyoming sentencing. The court denied credit for the 259 days he spent in Iowa prior to resolution of the Iowa case, finding that this period of confinement was attributable to his Iowa offenses, not solely to the Wyoming charge. The appellant filed a motion to correct his sentence and also sought appointment of counsel for his appeal. The district court denied both motions.Upon review, the Supreme Court of Wyoming held that the appellant is not entitled to credit for the 259 days of Iowa confinement because his incarceration during that time was due to independent Iowa criminal charges and would have persisted regardless of his ability to post bond in Wyoming. The court also determined that the district court’s judgment and sentence complied with Rule 32 requirements. Additionally, the Supreme Court of Wyoming concluded it lacks jurisdiction to consider the denial of appointed counsel because the appellant did not properly appeal that order. The district court’s denial of the motion to correct an illegal sentence was affirmed. View "Melber v. The State of Wyoming" on Justia Law

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