Justia Wyoming Supreme Court Opinion Summaries

Kenneth Charles Hoffman was convicted by a jury of five counts of sexual abuse of his minor stepdaughter, SD. The incident occurred on March 10, 2023, when SD, after consuming alcohol and marijuana provided by Hoffman, was sexually assaulted by him. The next morning, SD reported the incident, and a sexual assault examination revealed seminal fluid on a tampon she had used, though the DNA was insufficient to identify its source. SD had disclosed to law enforcement that she had been sexually active with someone else about a week and a half before the incident.The District Court of Weston County reviewed the case and denied Hoffman's motion to introduce evidence of SD’s prior sexual activity, which he argued would explain the presence of the seminal fluid. The court ruled that the probative value of this evidence did not outweigh its prejudicial effect, as required by Wyoming’s rape shield statute. Consequently, Hoffman was found guilty on all charges and sentenced to 40 to 50 years in prison.The Supreme Court of Wyoming reviewed the case and upheld the lower court's decision. The court held that the district court did not abuse its discretion in excluding the evidence of SD’s prior sexual activity. The Supreme Court noted that Hoffman failed to establish a material connection between the prior sexual activity and the seminal fluid found, as the DNA evidence neither included nor excluded him. The court affirmed that the probative value of the evidence did not substantially outweigh its prejudicial effect, thus affirming Hoffman's conviction and sentence. View "Hoffman v. The State of Wyoming" on Justia Law

Danny Jarvis pled guilty to burglary in violation of Wyoming law. Before sentencing, he filed a motion to withdraw his guilty plea, which the district court denied. He was subsequently sentenced to seven to ten years in prison. Jarvis appealed, claiming the district court abused its discretion by denying his motion to withdraw his guilty plea.The district court of Weston County initially set Jarvis' bond at $10,000 cash, which was later reduced to a $10,000 personal surety bond to allow him to seek employment and attend drug treatment. Jarvis entered residential drug treatment but left to obtain medical care. At the change of plea hearing, Jarvis agreed to plead guilty to burglary in exchange for the dismissal of a felony property destruction charge. He confirmed there was no plea agreement regarding his sentence other than owing restitution. The court accepted his guilty plea after ensuring it was made knowingly and voluntarily.Jarvis later filed a pro se motion to withdraw his guilty plea, claiming he was promised a "global deal" that included the dismissal of a DUI charge in a separate case. He argued this promise was not fulfilled, rendering his plea involuntary. The district court held a hearing, allowed Jarvis to proceed pro se, and took the motion under advisement. The court ultimately denied the motion, finding Jarvis failed to show a fair and just reason for withdrawal under Wyoming Rule of Criminal Procedure 32(d).The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court found that Jarvis did not assert his innocence, the State would not be prejudiced by withdrawal, and the delay in filing the motion was not substantial. However, the court determined Jarvis received close assistance of counsel, his plea was knowing and voluntary, and allowing withdrawal would waste judicial resources. The court concluded that the district court did not abuse its discretion in denying Jarvis' motion to withdraw his guilty plea. View "Jarvis v. The State of Wyoming" on Justia Law

In August 2021, Sean Halling applied for a variance from the Town of Afton to build an accessory building larger than the 900 square feet allowed by the local development code. The variance was approved by the Town Council in September 2021. In February 2022, the Zoning Administrator approved a modification to increase the building's size without public notice. The appellants, neighbors of Mr. Halling, observed the construction and became concerned about the building's size and potential use. They sent a letter to the Town in October 2022 and filed a declaratory judgment action in December 2022.The District Court of Lincoln County dismissed the appellants' action, concluding they failed to exhaust administrative remedies and that the matter was moot due to changes in the local development code allowing buildings of the size in question without a variance. The appellants appealed the decision.The Wyoming Supreme Court reviewed the case and affirmed the district court's decision. The court held that the appellants were required to exhaust administrative remedies specified in the Afton Land Development Code before seeking judicial intervention. The court found that the appellants did not appeal the Zoning Administrator's decision to the Town Council acting as the Board of Adjustment within the required timeframe. The court also concluded that the Town Council was acting in its capacity as the Board of Adjustment when it approved the initial variance, and the appellants failed to appeal that decision within a reasonable time. The court emphasized the importance of following prescribed administrative processes for resolving zoning disputes. View "Sorensen v. Halling" on Justia Law

Nicholas Hull sued North Lincoln Hospital District and several medical professionals for negligence in the death of his newborn son, Eli Hull. Canessa Hull, Nicholas's wife, went into labor on August 9, 2021, and was admitted to Star Valley Health. Due to complications during labor, Eli was born with a double-knotted nuchal cord and did not survive. The Hulls were initially informed by the attending doctors that the nuchal cord was the sole cause of Eli's death. However, in April 2023, Dr. Burk, an anesthesiologist, revealed that Eli's death was preventable and due to the failure to follow safety protocols during labor.The District Court of Lincoln County dismissed Mr. Hull’s complaint, ruling that his notice of governmental claim was untimely. The court found that the two-year period for filing the notice expired in September 2023, and Mr. Hull’s notice, submitted in July 2023, was defective. Mr. Hull argued that the period should be equitably extended due to the defendants' fraudulent concealment of the true cause of Eli’s death.The Supreme Court of Wyoming reviewed the case and affirmed the lower court's decision. The court held that Mr. Hull’s complaint did not adequately allege the elements required for equitable estoppel or equitable tolling. Specifically, the complaint failed to show that the delay in filing the notice was induced by the defendants' misinformation and that Mr. Hull acted on this misinformation in good faith, resulting in his failure to file a timely notice. Additionally, the complaint did not establish that the fraudulent concealment prevented Mr. Hull from complying with the statutory deadline, as he had over four months remaining to file a proper notice after discovering the concealment. Therefore, the court concluded that neither equitable estoppel nor equitable tolling applied, and the dismissal of the complaint was affirmed. View "Hull v. North Lincoln Hospital District" on Justia Law

Monique Huia Sullivan was convicted of voluntary manslaughter for the stabbing death of her fiancé, Andrew Moore. The couple, both sheep shearers from Australia and New Zealand, respectively, were part of a shearing crew working in Wyoming. On February 20, 2023, after a series of arguments and a difficult couple of days, Sullivan stabbed Moore once in the left side with a large kitchen knife. Sullivan was charged with second-degree murder, but the trial focused on whether she acted maliciously or in self-defense.The District Court of Lincoln County allowed John Moore, the victim's father, to testify and admitted a photograph of Moore while he was alive. Sullivan objected to both, arguing they were irrelevant and prejudicial. The court overruled her objections, and the jury found her guilty of voluntary manslaughter. She was sentenced to 12 to 17 years in prison.The Supreme Court of Wyoming reviewed the case and addressed two main issues: whether the district court abused its discretion in admitting the father's testimony and the photograph, and whether the prosecutor committed misconduct by advocating for their admission. The court found that the father's testimony about Moore's demeanor, favorite vacation spots, and the family dog was irrelevant and should not have been admitted. Similarly, the photograph was deemed irrelevant and should not have been admitted in the State's case-in-chief.However, the court concluded that the admission of this evidence was harmless error and did not materially prejudice Sullivan. The State's case was strong, with multiple witnesses and Sullivan's own admissions undermining her self-defense claim. The court also found no prosecutorial misconduct, as Sullivan failed to establish material prejudice from the prosecutor's actions. The Supreme Court of Wyoming affirmed the lower court's decision. View "Sullivan v. The State of Wyoming" on Justia Law

Clint Wayne Hammell pled guilty to felony possession of methamphetamine in May 2023 and was sentenced to four to five years of imprisonment, suspended in favor of three years of supervised probation. His probation was revoked twice in November 2023 and February 2024, with his sentence resuspended each time. After the second revocation, he was ordered to apply for and complete an adult community corrections (ACC) program, which he did at the Casper Re-Entry Center (CRC).In April 2024, the State petitioned to revoke Hammell's probation again, alleging he failed to report to a scheduled appointment with his probation agent on March 26, 2024, and did not return to the CRC, leading to his classification as an escapee. At the evidentiary hearing, his probation agent testified about his absence and subsequent arrest on March 28. The CRC case manager supervisor and a Casper Police Department officer also testified about his failure to report and his arrest.The district court found that Hammell violated his probation conditions and that his violations were willful, noting his failure to use his phone to arrange transportation back to the CRC. Consequently, the court revoked his probation and imposed the underlying sentence of four to five years with credit for time served. Hammell appealed the decision.The Supreme Court of Wyoming reviewed the case, focusing on whether the district court abused its discretion in finding Hammell's violations willful. The court upheld the district court's decision, stating that the evidence supported the finding of willfulness, as Hammell did not make efforts to contact his probation agent or return to the CRC. The court affirmed the revocation of Hammell's probation. View "Hammell v. The State of Wyoming" on Justia Law

Carolyn Aune was convicted of first-degree murder following the death of PW, a two-year-old child, due to child abuse. On March 27, 2021, PW was brought to the emergency room by her father, Moshe Williams, unresponsive and with multiple injuries, including bruises, fractures, and a transected small intestine. Despite being life-flighted to Children’s Hospital in Denver, PW succumbed to her injuries on April 4, 2021. The autopsy revealed that PW died from blunt force trauma to the abdomen, leading to sepsis and organ failure.The District Court of Park County charged both Williams and Aune with aggravated child abuse, later amended to first-degree murder after PW’s death. Aune’s trial was severed from Williams’s. During the trial, Aune testified that she witnessed Williams inflict the fatal injury on PW but did not seek medical help, believing PW was fine. The State argued that Aune either intentionally or recklessly caused PW’s injuries by failing to get prompt medical attention, which led to PW’s death.The Wyoming Supreme Court reviewed the case, focusing on whether the State presented sufficient evidence to support Aune’s conviction for felony child abuse as a requisite offense for first-degree murder and whether the prosecutor committed misconduct by misstating the law. The court found that the State provided sufficient evidence showing Aune recklessly inflicted physical injury on PW by failing to seek medical care, which led to PW’s death. The court also determined that the prosecutor did not misstate the law, as the statutes in question encompass injuries inflicted through acts of omission.The Wyoming Supreme Court affirmed Aune’s conviction, holding that the evidence supported the jury’s finding that Aune’s failure to seek medical care for PW constituted reckless infliction of physical injury, leading to PW’s death and justifying the first-degree murder conviction. View "Aune v. State" on Justia Law

Eiden Construction, LLC (Eiden) entered into a subcontract with Hogan & Associates Builders, LLC (Hogan) for earthwork and utilities on a school construction project. Hogan sued Eiden and its bonding company, AMCO Insurance Company (AMCO), for breach of contract, claiming Eiden failed to complete its work, including draining sewage lagoons and constructing a fire pond. Eiden counterclaimed for unpaid work, arguing it was not responsible for draining the lagoons and that Hogan did not comply with the subcontract’s notice and opportunity to cure provisions. AMCO argued it was not liable under the performance bond because Eiden did not breach the subcontract and Hogan did not provide proper notice.The District Court of Uinta County found for Hogan on the claim regarding the sewage lagoons but not on other claims, ruling AMCO was not liable under the bond due to lack of notice. Eiden and Hogan both appealed. Eiden argued the court erred in finding it responsible for draining the lagoons and in awarding Hogan damages billed to an associated company. Hogan contended the court erred in not awarding damages for other work and in its calculation of prejudgment interest.The Wyoming Supreme Court affirmed the lower court’s decision. It held Eiden breached the subcontract by not draining the lagoons and that Hogan was entitled to recover costs for supplementing Eiden’s work. The court found Eiden’s late completion of the septic system justified Hogan’s directive to expedite lagoon drainage. It also ruled Hogan properly paid the supplemental contractors, despite invoices being sent to an associated company. The court rejected Hogan’s claims for additional damages, concluding Eiden complied with the notice to cure provisions for the fire pond and other work. The court also upheld the lower court’s calculation of prejudgment interest, applying the offset before calculating interest. View "Hogan & Associates Builders, LLC v. Eiden Construction, LLC" on Justia Law

Vincent Hayes was convicted of second-degree murder for shooting and killing his father, William Johnson, during an argument at their home in Casper, Wyoming. Hayes claimed he acted in self-defense, believing his father was about to shoot him. After the shooting, Hayes attempted to clean up the scene, hid the weapon, and initially fabricated a story about an intruder. He later admitted to the police that he made up the story because he thought no one would believe his self-defense claim.The District Court of Natrona County instructed the jury that it could infer malice from Hayes' use of a deadly weapon, despite his self-defense claim. Hayes did not object to this instruction at trial. The jury found Hayes guilty of second-degree murder, and he was sentenced to 50 to 75 years in prison.The Wyoming Supreme Court reviewed the case, focusing on whether the district court committed plain error by instructing the jury that it could infer malice from the use of a deadly weapon. The court held that the instruction was proper and did not violate any clear and unequivocal rule of law. The instruction was consistent with Wyoming precedent, which allows for permissive inference instructions if they are not mandatory and the state still bears the burden of proving each element of the crime beyond a reasonable doubt. The court found that the connection between the use of a deadly weapon and the inference of malice was justified by the facts of the case. Consequently, the Wyoming Supreme Court affirmed Hayes' conviction. View "Hayes v. State" on Justia Law

In 2020, Wagonhound Land & Livestock, LLC purchased the 14,000-acre Tomahawk Ranch in Converse County, Wyoming. Shortly after, Wagonhound filed an action to quiet title to approximately forty acres that Boot Ranch, LLC had occupied and used since at least 1984. Boot Ranch counterclaimed for adverse possession of the property. The district court found that Boot Ranch had made a prima facie showing of adverse possession but concluded that Wagonhound had rebutted this claim by proving the existence of a fence of convenience and neighborly accommodation, thus quieting title in Wagonhound’s favor.The District Court of Converse County held a four-day bench trial and found that Boot Ranch had continuously used the disputed property for grazing, recreation, hunting, and fishing since at least 1984. However, the court concluded that the fence partially enclosing the property was a fence of convenience and that the use of the property was a result of neighborly accommodation. Consequently, the court ruled that Boot Ranch’s use was permissive, defeating its adverse possession claim. Boot Ranch appealed the decision.The Supreme Court of Wyoming reviewed the case and found that the evidence did not support the district court’s findings that the fence was one of convenience or that the use of the property was a neighborly accommodation. The court noted that there was no evidence of a convenience served by the fence and that the actions of removing trespassing cattle indicated assertions of exclusive ownership rather than permissive use. The Supreme Court of Wyoming reversed the district court’s decision and remanded the case for entry of an order quieting title to the disputed property in favor of Boot Ranch. View "Boot Ranch, LLC v. Wagonhound Land & Livestock Co., LLC" on Justia Law